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1JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAWy P.C.
2 1901 Avenucupf the Stars Suite #450
3 Los Angeles, Califomia 90067,
Tel.: (818) 456-6i68^;Fax: (8:88)^505-0868
4 Email: josh@falakassajaw.com tfP/EiPBRS £0
5 ARASH S. K H O I R O W S H A H I (SBN: 293246)
LIBERTY MAN L X W , P.C. ^ AUG - 3 2022
6 lOlOF Street,-^Ster300 '
Sacramento, GalifOmia*95814 /
7 Tel.: (916) 573-0469; Fax: (866) 700-0787,. By:: -H: PFMFI Tnw •
•' . V UeputyXlerk..
Email: ash@libertymarilaw,cpm A
8
Attomeys for Plaintiff,
9 SAJIDA ZAMAN
10 SUPERIOR COURT OF CALIFORNL\
11 COUNTY OF SACRAMENTO
12
13 SAJIDA ZAMAN, CASE NO : 34-2019-00252121
RESERVATION ID: 2664200
14 Plaintiff,
DECLARATION: OF ARASH S.
15 vs. KHOSRGWSHMI IN-SUPPORT OF
MOTION TO COMPEL DISCOVERY
16 LIQUI-BOX CORPORATION; aiid DOES 1 MSPONSES ;AS T b SPECIAL
through 20, inclusive, • INTERROGAtbRIES, SET FIVE, AND
17 MONETARY SANCTIONS
Defendants.
18 Date:^October 18,2022
Time: 1:30pm "
BY FAX
19 Dept.:53; - /'
20 TnaliDate:;Se^^^
21 I, ARASFI KHOSROWSHAIfl, declare^^^
22 1. I aim an attorney licensed to practice law in the State of California. My Ste^ Bar Number
23 is 293246. / ^ . '
24 2. I represent .Plaintiff Sajida Zaniaai/("Plaind have
25 knowledge of thie facts^steted herein aridxan testify competeritiy
26 3. On May 27^ 20i22 I on behalf of Plaintiff sei-ved her •fifth" set pif; Special vlnteirOgatories
27 propoiihded against Defendant yia email. (Attached as Exhibit A is a' tme and cpirect copy
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: DECLARATION.ORARASH KHOSROWSHAHI^IN SUPPORT
1 of Plaintiff Sajida Zaman's Special Interrogatories.to Defendant Liqui-Box Corporation
2 (Set Five).) The Special Interi-ogatories were concurrently served with Plaintiff s Requests
3 for Admissions (Set, One) ("RFAs") and Fonn biterrogatoriesT—General^ Set Two
4 ("FROGs"). .
5 4. The Special Iriterrogatpries cp^ inten;ogatories in sum asking for:
6 (1) Defendant's insurance retention (Special-Interrogatories, SetiFive,:No..43);
7 (2) when the insurer wasfirstnotified of this case {Id., No. 44);
8 (3) safety trainings Defendant contends it provided Plaintiff and when .they occurred {Id.
9 Nos. 45-46); .
10 (4) whether Defendantf:;informed Plaintiff-it^was under; O Violator
11 Enforcement Program" yvhen jt conducted trainings' {Id., Np. 47);
12 (5) all steps Defendant toOkCto'evaluate modified work duties to accommodate Plaintifi
13 (M,No.48); ^ .
14 (6) the date PlaintifPs injury^wasfirstidentified {Id., No;.,49j;
15 (7) the percentage of employees who missed work due to;cumulatiye trauma injuries or not
16 in the lastfiveyears (/i^.i Nos. ,5.0-51.);
17 (8) all facts/witnesses/docunients in support of Defendant's contention that defective
18 trolleys Plaintiff worked on were repaired (M, No-52-54);
19 (9) whether Defendant notified Plaintiff policy, that OSHA cited
20 and convicted them for rnachine;safety, proced^ No. 55);
21 (10) all facts/documents in support; of^.tfie.contention that De^^ employees to
22 identify disease, condition or iiijury/from' their signs 2md5symptoms (^^^ Nos. 56-57);
23 (11) all facts/witnesses/doc
24 with a left kiiee and hamstring pain :in relation tocher 4 P^^^ Review
25 ,,(A/Nos. 58-59);^ . ' '; ' \..; / ,
27 • - ,• :
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DECLARATION pF ARASH KHOSROWSHAHI IN SUPPORT
v . ^l-^ '- 2of4 •
1 (12) whether Defendant contends Plaintiff injuries were caused by her failure to follow
2 Defendant's instructions provided in her training on proper operation of mega tote carts
3 and all supporting facts {Id., Nos. 60-61);
4 (13) whether attendance for such mega tote cart trainings were mandatory {Id., No. 62);
5 (14) the identities of all persons present for mega tote cart trainings, as well as all
6 documents reflecting the matters presented at the trainings {Id., Nos. 63-64); and
7 (15) all facts supporting Defendant's contention that Plaintiffs actions leading to her
8 injuries were inconsistent with any trainings provided. {Id., No. 65.)
9 (See Exhibit A.)
10 5. As of this writing Defendant did not serve any objections or responses to the Special
11 Interrogatories, Set Five.
12 6. I am a graduate of the University of Califomia, Berkeley School of Law ("Boalt Hall"), a
13 Top 14 law school. I further graduated with a Bachelor of Science in Mathematics (Honors)
14 and a Bachelor of Arts in Philosophy (Highest Honors) from the University of Califomia,
15 Davis in 2009.1 mn a solo practice in Sacramento, Califomia, and have been practicing
16 law since December 2013.1 primarily handle unlimited civil litigation cases in employment
17 law, which include class-action wage-and-hour cases as well as wrongful termination
18 cases. I practice throughout the State of Califomia, having litigated cases successfiilly in
19 the greater Sacramento Area, the Bay Area, and the greater Los Angeles area. I have also
20 negotiated six-figure/seven-figure settlements for class-action wage-and-hour matters as
21 well as six-figure settlements for wrongful termination matters. I was selected as a Super
22 Lawyer Rising Star in Northern Califomia in 2020, 2021, and 2022, a distinction that is
23 reserved for the top 2.5% of lawyers practicing less than 10 years. For these reasons, I
24 believe an hourly rate of $500 is a reasonable hourly rate.
25 7. I spent 1.3 hours researching and drafting this instant Motion and related documents herein
26 resulting in $650.00 in reasonable attomey's fees. Further, Plaintiff incurs a $60 motion
27
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
3 of 4
1 filing fee. I therefore respectfully request sanctions in the amount of $710.00 for reasonable
2 costs and attomey's fees.
3 I declare under penalty of perjury under the laws of the State of Califomia that the
4 foregoing is true and correct.
5 Dated: August 2, 2022
6
7 By:
Arash S. Khosrowshahi
8 Attomey for Plaintiff Sajida Zaman
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DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT
4 of 4
EXHIBIT A
JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
1901 Avenue ofthe Stars Suite # 450
Los Angeles, Califomia 90067
Tel.: (818) 456-6168
Fax: (888) 505-0868
Email: josh@falakassalaw.com
LIBERTY MAN LAW, P.C.
ARASH S. KHOSROWSHAHI (SBN: 293246)
1010 FStt-eet, Ste. 300
Sacramento, California 95814
Tel.: (916) 573-0469
Fax: (866) 700-0787
Email: ash@libertymanlaw.cora
Attomeys for Plaintiff
SAHDA ZAMAN
10
SUPERIOR COURT OF CALIFORNIA
II
COUNTY OF SACRAMENTO
12
13
SAJIDA ZAMAN, an individual, CASE NO.: 34-2019-00252121
14 PLAINTIFF SAJIDA ZAMAN'S SPECIAL
Plaintiff, INTERROGATORIES TO DEFENDANT
15 vs. LIQUI-BOX CORPORATION (SET FIVE)
LIQUI-BOX CORPORATION, and DOES I
16 through 20, inclusive,
17 Defendants.
18
19
20
PROPOUNDING PARTY SAJIDA ZAMAN
21
RESPONDING PARTY LIQUI-BOX CORPORATION
22 SET NUMBER FIVE (5)
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PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
3
Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX
4 CORPORATION answer under oath within thirty (30) days, pursuant to Califomia Code of Civil
5 Procedure §§ 2030.010 et seq., the following interrogatories.
6 In answering these interrogatories please fiimish such information as is available to you,
7 and not merely that which you know of your personal knowledge. This means that you are to
8 furnish infonnation which is available to you or is within the knowledge of your attomeys, or
their agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et
9
seg.)
H)
If any of these interrogatories cannot be answered in full, you are required to answer to
II
the extent possible, specifying the reason for your inability to answer the remainder and stating
12
whatever information or knowledge you have concerning the unanswered portion.
13 DEFINITIONS
14 Words that are in CAPITALS are defined as follows:
15 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and
16 refers to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies
17 (including LB Hold Co.), its agents, representatives, investigators, employees, contractors,
IX govemmental entities, insurance companies, their agents, their employees, their investigators,
their representatives and anyone else acting on Defendant LIQUI-BOX CORPORATION behalf
1^
except its herein attomeys.
20
(b) PERSON includes a natural person, firm, association, organization, partoership,
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business, trust, limited liability company, corporation, or public entity.
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PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
I (c) "REPRIMAND" or "REPRIMANDED" as used herein means any punishment,
2
suspension, demotion, loss of pay, failure or refusal to promote, failure or refusal to hire, or any
3
other action or failure to act that adversely affects the employee'srightsor interests.
4
(d) "CSB POLICY" as used herein means LIQUI-BOX's "Critical Safety Behavior
5 policy".
6 (e) "SAFETY TRAINING" as used herein means and includes all trainings and
7 instmctions, including any question-answer sessions, that YOU provided to Plaintiff during any
8 period of Plaintiff's employment, including monthly safety meetings, mandatory safety
^ meetings, safety committee meetings, OSHA trainings, first-aid trainings, and trainings on
10 LIQUI-BOX's "Critical Safety Behavior policy."
II
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PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
I SPECIAL INTERROGATORIES
2 SPECIAL INTERROGATORY NO. 43:
What is the amount of the SIR (self-insured retention) of LB Hold Co.'s Employment
3
Practices Policy (Policy No. G71187019001) as it relates to the claims brought by Plaintiff m
4
this action?
5
SPECIAL INTERROGATORY NO. 44:
6
On what date did YOUfirstnotify Westchester Surplus Lines Insurance Company
7
(Chubb) of any of the facts or circumstances of Plaintiff's claim?
S
SPECIAL INTERROGATORY NO. 45:
9
If YOU contend that YOU provided training to Plaintiff on "SAFETY TRAINING",
10 identify each such SAFETY TRAINING by the date YOU provided it.
II SPECIAL INTERROGATORY NO. 46:
12 For each SAFETY TRAINING that YOU identified in response to the Special
13 Interrogatory immediately preceding this one, indicate whether YOU did so while YOU were in
14 OSHA's "Severe Violator Enforcement Program" as a result of failing to adequately train
15 YOUR employees on safety processes.
SPECIAL INTERROGATORY NO. 47:
17 For each occasion on which YOU contend YOU trained Plaintiff on safety processes,
18 indicate whether YOU infonned Plaintiff that YOU were in OSHA's "Severe Violator
19 Enforcement Program" as a result of failing to adequately train YOUR employees on safety
20 processes.
21 SPECIAL INTERROGATORY NO. 48:
Describe all steps YOU took at any time in 2019 to evaluate modified work duties that
22
would accommodate PlaintifTs work restrictions.
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PLAINTIFF SAnDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
SPECIAL INTERROGATORY NO. 49:
For each particular injury that YOU contend Plaintiff failed to "immediately report", state
3 the date on which the injury was fu-st identified by any PERSON qualified to do so.
4 SPECIAL INTERROGATORY NO. 50;
5 Ofthe total days that YOUR packer employees missedfromwork over the past 5 years as
6 a resuh of injuries, what percentage was attributed to Cumulative Trauma injuries?
7 SPECIAL INTERROGATORY NO. 51:
8 Ofthe total days that YOUR operator employees missedfromwork over the past 5 years
9 as a result of injuries, what percentage was attributed to injuries other than Cumulative Trauma
10 injuries?
SPECIAL INTERROGATORY NO. 52:
II
Please identify, by name, address and telephone number all PERSON(S) with personal
12
knowledge of YOUR contention that "all of the mega tote cart wheels were replaced three
13
months ago" as YOU claimed in YOUR "4 Panel EHS Disciplinary Review] that you produced
14
as LBC000062-63.
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SPECIAL INTERROGATORY NO. 53;
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Please identify, by date, source, location and custodian, all DOCUMENTS that RELATE
17
to YOUR contention that "all of the mega tote cart wheels were replaced three months ago" as
IX YOU claimed in YOUR "4 Panel EHS Disciplmary Review" that you produced as
19 LBC000062-63.
20 //
21 //
22 //
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PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
SPECIAL INTERROGATORY NO. 54;
Please state all facts that support YOUR contention that "all of the mega tote cart wheels
were replaced three months ago" as YOU claimed in YOUR "4 Panel EHS Disciplinary Review
4 that you produced as LBC000062-63."
5 SPECIAL INTERROGATORY NO. 55:
6 When YOU obtained Plaintiffs signed agreement to the CSB Policy in May 2018, did
7 YOU disclose to Plaintiff the fact that OSHA had cited and convicted YOU in March 2018 for
8 numerous serious and repeat violations of machine safety procedures?
9 SPECIAL INTERROGATORY NO. 56;
Please state all facts that support YOUR contention, if YOU do so contend, that YOU
10
trained YOUR employees in the process of identifying a disease, condition, or injuryfromits
signs and symptoms.
SPECIAL INTERROGATORY NO. 57:
13
Please identify, by date, source, location and custodian, all DOCUMENTS that RELATE
14
to YOUR contention, if YOU do so contend, that YOU trained YOUR employees in the process
15
of identifying a disease, condition, or injuryfromits signs and symptoms.
16 SPECIAL INTERROGATORY NO. 58:
17 Please state all facts diat support YOUR contention, in YOUR "4 Panel EHS Disciplinary
IX Review," which YOU produced as LBC000062-63, that Plaintiff "was diagnosed with a left knee
19 and hamstring sprain."
20 SPECIAL INTERROGATORY NO. 59:
21 Please identify, by date, source, location and custodian, all DOCUMENTS that RELATE
22 to YOUR contention, in YOUR "4 Panel EHS Disciplinary Review," which YOU produced as
23 LBC000062-63, that Plaintiff "was diagnosed with a left knee and hamstring sprain."
PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
1 SPECIAL INTERROGATORY NO. 60:
Do YOU contend that Plaintiff's injuries were caused by Plaintiff's failure to follow any
3
instmctions YOU provided to Plaintiff infrainingher in the proper operation of a mega tote cart
4 (hereinafter, the "CART TRAINING(S)") ?
5 SPECIAL INTERROGATORY NO. 61;
6 Please state all facts that support YOUR contention that Plaintiffs injuries were caused
7 by Plaintiff's failure to follow any aspect ofthe CART TRAINING(S), if YOU do so contend.
8 SPECIAL INTERROGATORY NO. 62:
9 For each CART TRAINING that YOU claim YOU provided to Plaintiff, please indicate
10 whether attendance at the training was voluntaty or mandatory for Plaintiff.
II SPECIAL INTERROGATORY NO. 63:
For each CART TRAINING that YOU claim YOU provided to Plaintiff, please identify,
12
by name, address and telephone number all PERSON(S) who were present for any portion ofthe
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training.
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SPECIAL INTERROGATORY NO. 64:
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For each CART TRAINING that YOU claim YOU provided to Plaintiff, please identify
16
all DOCUMENTS that reflect the matters presented, discussed, asked, or otherwise
17
communicated among any PERSON(S) at the training.
IX SPECIAL INTERROGATORY NO. 65:
19 Please state all facts that support YOUR contention, if YOU do so contend, that
20 Plaintiffs actions leading to her injury were inconsistent with any of the CART TRAINING(S)
21 that YOU provided to her
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PLAINTIFF SAHDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
Dated: May 27, 2022 FALAKASSA LAW, P.C.
LIBERTY MAN LAW, P.C.
4 BY:
5
JOSHUA S. FALAKASSA
6 ARASH KHOSROWSHAHI
Attomeys for Plaintiff SAJIDA ZAMAN
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PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION (SET FOUR)
1 JOSHUA S. FALAKASSA fSBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450
Los Angeles, Califomia 90067
3 Tel.:f818) 456-6168
Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5
LIBERTY MAN LAW, P.C.
6 ARASH S. KHOSROWSHAHI (SBN: 293246)
1010 F Street, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469
8 Fax: (866) 700-0787
9 Email: ash@libertymanlaw.com
10 Attomeys for Plaintiff
SAJIDA ZAMAN
11
12
SUPERIOR COURT OF CALIFORNIA
13
COUNTY OF SACRAMENTO
14
15 SAJIDA ZAMAN, an individual. CASE NO.: 34-2019-00252121
16 Plaintiff, DECLARATION OF ARASH
KHOSROWSHAHI REGARDING THE
vs. NEED FOR ADDITIONAL SPECIAL
17
INTERROGATORIES TO DEFENDANT
LIQUI-BOX CORPORATION, and DOES 1
18 through 20, inclusive.
[Served Concurrently with Plaintiffs Special
19 Interrogatories, Set Five]
20 Defendants.
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1
DECLARATION OF ARASH KHOSROWSHAHI REGARDING THE NEED FOR ADDITIONAL SPECIAL
INTERROGATORIES TO DEFENDANT
1 DECLARATION OF ARASH KHOSROWSHAHI
2 1, Arash Khosrowshahi, declare and state as follows:
3 1. 1 am presently the attomey for plaintiff Sajida Zaman ("Plaintiff'), a party to this
4 action.
5 2. I am propounding to defendant Liqui-Box Corporation ("Defendant") the attached
6 Special Interrogatories, Set Number Five (5).
7 3. This set of intenogatories will cause the total number of specially prepared
8 interrogatories propounded to the party to whom they are directed to exceed the number of
9 specially prepared mterrogatories permitted by Section 2030.030 of the Code of Civil Procedure.
10 4. 1 have previously propounded a total of thirty-three (42) specially prepared
11 interrogatories to this party.
12 5. This set of interrogatories contains a total of twenty-three (23) specially prepared
13 interrogatories.
14 6. I am familiar with the issues and the previous discovery conducted by all of the
15 parties to this case.
16 7. I have personally examined each of the questions in this set of interrogatories.
17 8. This number of questions is warranted under Section 2030.040 of the Code of Civil
18 Procedure because of the quantity and nature of the existing and potential issues involved, and the
19 expedience and benefit to each of the parties that will result in using this form of discovety to
20 obtain certain information about Defendant's positions, arguments and defenses.
21 9. None of the questions in this set of interrogatories is being propounded for any
22 improper purpose, such as to harass the party or the attomey for the party to whom it is directed or
23 to cause uimecessary delay or needless increase in the cost of litigation.
24 I declare under penalty of perjury under the laws of the State of Califomia that the
25 foregoing is tme and correct, and that this declaration was executed on May 27, 2022 at
26 Sacramento, Califomia.
27
Arash S. Khosrowshahi
28
DECLARATION OF ARASH KHOSROWSHAHI REGARDING THE NEED FOR ADDITIONAL SPECIAL
INTERROGATORIES TO DEFENDANT
Preview
•••V 1JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAWy P.C. 2 1901 Avenucupf the Stars Suite #450 3 Los Angeles, Califomia 90067, Tel.: (818) 456-6i68^;Fax: (8:88)^505-0868 4 Email: josh@falakassajaw.com tfP/EiPBRS £0 5 ARASH S. K H O I R O W S H A H I (SBN: 293246) LIBERTY MAN L X W , P.C. ^ AUG - 3 2022 6 lOlOF Street,-^Ster300 ' Sacramento, GalifOmia*95814 / 7 Tel.: (916) 573-0469; Fax: (866) 700-0787,. By:: -H: PFMFI Tnw • •' . V UeputyXlerk.. Email: ash@libertymarilaw,cpm A 8 Attomeys for Plaintiff, 9 SAJIDA ZAMAN 10 SUPERIOR COURT OF CALIFORNL\ 11 COUNTY OF SACRAMENTO 12 13 SAJIDA ZAMAN, CASE NO : 34-2019-00252121 RESERVATION ID: 2664200 14 Plaintiff, DECLARATION: OF ARASH S. 15 vs. KHOSRGWSHMI IN-SUPPORT OF MOTION TO COMPEL DISCOVERY 16 LIQUI-BOX CORPORATION; aiid DOES 1 MSPONSES ;AS T b SPECIAL through 20, inclusive, • INTERROGAtbRIES, SET FIVE, AND 17 MONETARY SANCTIONS Defendants. 18 Date:^October 18,2022 Time: 1:30pm " BY FAX 19 Dept.:53; - /' 20 TnaliDate:;Se^^^ 21 I, ARASFI KHOSROWSHAIfl, declare^^^ 22 1. I aim an attorney licensed to practice law in the State of California. My Ste^ Bar Number 23 is 293246. / ^ . ' 24 2. I represent .Plaintiff Sajida Zaniaai/("Plaind have 25 knowledge of thie facts^steted herein aridxan testify competeritiy 26 3. On May 27^ 20i22 I on behalf of Plaintiff sei-ved her •fifth" set pif; Special vlnteirOgatories 27 propoiihded against Defendant yia email. (Attached as Exhibit A is a' tme and cpirect copy 28 : DECLARATION.ORARASH KHOSROWSHAHI^IN SUPPORT 1 of Plaintiff Sajida Zaman's Special Interrogatories.to Defendant Liqui-Box Corporation 2 (Set Five).) The Special Interi-ogatories were concurrently served with Plaintiff s Requests 3 for Admissions (Set, One) ("RFAs") and Fonn biterrogatoriesT—General^ Set Two 4 ("FROGs"). . 5 4. The Special Iriterrogatpries cp^ inten;ogatories in sum asking for: 6 (1) Defendant's insurance retention (Special-Interrogatories, SetiFive,:No..43); 7 (2) when the insurer wasfirstnotified of this case {Id., No. 44); 8 (3) safety trainings Defendant contends it provided Plaintiff and when .they occurred {Id. 9 Nos. 45-46); . 10 (4) whether Defendantf:;informed Plaintiff-it^was under; O Violator 11 Enforcement Program" yvhen jt conducted trainings' {Id., Np. 47); 12 (5) all steps Defendant toOkCto'evaluate modified work duties to accommodate Plaintifi 13 (M,No.48); ^ . 14 (6) the date PlaintifPs injury^wasfirstidentified {Id., No;.,49j; 15 (7) the percentage of employees who missed work due to;cumulatiye trauma injuries or not 16 in the lastfiveyears (/i^.i Nos. ,5.0-51.); 17 (8) all facts/witnesses/docunients in support of Defendant's contention that defective 18 trolleys Plaintiff worked on were repaired (M, No-52-54); 19 (9) whether Defendant notified Plaintiff policy, that OSHA cited 20 and convicted them for rnachine;safety, proced^ No. 55); 21 (10) all facts/documents in support; of^.tfie.contention that De^^ employees to 22 identify disease, condition or iiijury/from' their signs 2md5symptoms (^^^ Nos. 56-57); 23 (11) all facts/witnesses/doc 24 with a left kiiee and hamstring pain :in relation tocher 4 P^^^ Review 25 ,,(A/Nos. 58-59);^ . ' '; ' \..; / , 27 • - ,• : 28 DECLARATION pF ARASH KHOSROWSHAHI IN SUPPORT v . ^l-^ '- 2of4 • 1 (12) whether Defendant contends Plaintiff injuries were caused by her failure to follow 2 Defendant's instructions provided in her training on proper operation of mega tote carts 3 and all supporting facts {Id., Nos. 60-61); 4 (13) whether attendance for such mega tote cart trainings were mandatory {Id., No. 62); 5 (14) the identities of all persons present for mega tote cart trainings, as well as all 6 documents reflecting the matters presented at the trainings {Id., Nos. 63-64); and 7 (15) all facts supporting Defendant's contention that Plaintiffs actions leading to her 8 injuries were inconsistent with any trainings provided. {Id., No. 65.) 9 (See Exhibit A.) 10 5. As of this writing Defendant did not serve any objections or responses to the Special 11 Interrogatories, Set Five. 12 6. I am a graduate of the University of Califomia, Berkeley School of Law ("Boalt Hall"), a 13 Top 14 law school. I further graduated with a Bachelor of Science in Mathematics (Honors) 14 and a Bachelor of Arts in Philosophy (Highest Honors) from the University of Califomia, 15 Davis in 2009.1 mn a solo practice in Sacramento, Califomia, and have been practicing 16 law since December 2013.1 primarily handle unlimited civil litigation cases in employment 17 law, which include class-action wage-and-hour cases as well as wrongful termination 18 cases. I practice throughout the State of Califomia, having litigated cases successfiilly in 19 the greater Sacramento Area, the Bay Area, and the greater Los Angeles area. I have also 20 negotiated six-figure/seven-figure settlements for class-action wage-and-hour matters as 21 well as six-figure settlements for wrongful termination matters. I was selected as a Super 22 Lawyer Rising Star in Northern Califomia in 2020, 2021, and 2022, a distinction that is 23 reserved for the top 2.5% of lawyers practicing less than 10 years. For these reasons, I 24 believe an hourly rate of $500 is a reasonable hourly rate. 25 7. I spent 1.3 hours researching and drafting this instant Motion and related documents herein 26 resulting in $650.00 in reasonable attomey's fees. Further, Plaintiff incurs a $60 motion 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 3 of 4 1 filing fee. I therefore respectfully request sanctions in the amount of $710.00 for reasonable 2 costs and attomey's fees. 3 I declare under penalty of perjury under the laws of the State of Califomia that the 4 foregoing is true and correct. 5 Dated: August 2, 2022 6 7 By: Arash S. Khosrowshahi 8 Attomey for Plaintiff Sajida Zaman 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ARASH KHOSROWSHAHI IN SUPPORT 4 of 4 EXHIBIT A JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 1901 Avenue ofthe Stars Suite # 450 Los Angeles, Califomia 90067 Tel.: (818) 456-6168 Fax: (888) 505-0868 Email: josh@falakassalaw.com LIBERTY MAN LAW, P.C. ARASH S. KHOSROWSHAHI (SBN: 293246) 1010 FStt-eet, Ste. 300 Sacramento, California 95814 Tel.: (916) 573-0469 Fax: (866) 700-0787 Email: ash@libertymanlaw.cora Attomeys for Plaintiff SAHDA ZAMAN 10 SUPERIOR COURT OF CALIFORNIA II COUNTY OF SACRAMENTO 12 13 SAJIDA ZAMAN, an individual, CASE NO.: 34-2019-00252121 14 PLAINTIFF SAJIDA ZAMAN'S SPECIAL Plaintiff, INTERROGATORIES TO DEFENDANT 15 vs. LIQUI-BOX CORPORATION (SET FIVE) LIQUI-BOX CORPORATION, and DOES I 16 through 20, inclusive, 17 Defendants. 18 19 20 PROPOUNDING PARTY SAJIDA ZAMAN 21 RESPONDING PARTY LIQUI-BOX CORPORATION 22 SET NUMBER FIVE (5) 23 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 3 Plaintiff SAJIDA ZAMAN hereby requests that Defendant LIQUI-BOX 4 CORPORATION answer under oath within thirty (30) days, pursuant to Califomia Code of Civil 5 Procedure §§ 2030.010 et seq., the following interrogatories. 6 In answering these interrogatories please fiimish such information as is available to you, 7 and not merely that which you know of your personal knowledge. This means that you are to 8 furnish infonnation which is available to you or is within the knowledge of your attomeys, or their agents, employees, investigators or experts. (See Code of Civil Procedure §§ 2030.010 et 9 seg.) H) If any of these interrogatories cannot be answered in full, you are required to answer to II the extent possible, specifying the reason for your inability to answer the remainder and stating 12 whatever information or knowledge you have concerning the unanswered portion. 13 DEFINITIONS 14 Words that are in CAPITALS are defined as follows: 15 (a) "LIQUI-BOX", "YOU" or "YOUR" as used herein, includes, describes and 16 refers to Defendant LIQUI-BOX CORPORATION, its subsidiaries, its parent/holding companies 17 (including LB Hold Co.), its agents, representatives, investigators, employees, contractors, IX govemmental entities, insurance companies, their agents, their employees, their investigators, their representatives and anyone else acting on Defendant LIQUI-BOX CORPORATION behalf 1^ except its herein attomeys. 20 (b) PERSON includes a natural person, firm, association, organization, partoership, 21 business, trust, limited liability company, corporation, or public entity. 22 23 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) I (c) "REPRIMAND" or "REPRIMANDED" as used herein means any punishment, 2 suspension, demotion, loss of pay, failure or refusal to promote, failure or refusal to hire, or any 3 other action or failure to act that adversely affects the employee'srightsor interests. 4 (d) "CSB POLICY" as used herein means LIQUI-BOX's "Critical Safety Behavior 5 policy". 6 (e) "SAFETY TRAINING" as used herein means and includes all trainings and 7 instmctions, including any question-answer sessions, that YOU provided to Plaintiff during any 8 period of Plaintiff's employment, including monthly safety meetings, mandatory safety ^ meetings, safety committee meetings, OSHA trainings, first-aid trainings, and trainings on 10 LIQUI-BOX's "Critical Safety Behavior policy." II 12 13 14 15 16 17 JX 19 20 21 22 23 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) I SPECIAL INTERROGATORIES 2 SPECIAL INTERROGATORY NO. 43: What is the amount of the SIR (self-insured retention) of LB Hold Co.'s Employment 3 Practices Policy (Policy No. G71187019001) as it relates to the claims brought by Plaintiff m 4 this action? 5 SPECIAL INTERROGATORY NO. 44: 6 On what date did YOUfirstnotify Westchester Surplus Lines Insurance Company 7 (Chubb) of any of the facts or circumstances of Plaintiff's claim? S SPECIAL INTERROGATORY NO. 45: 9 If YOU contend that YOU provided training to Plaintiff on "SAFETY TRAINING", 10 identify each such SAFETY TRAINING by the date YOU provided it. II SPECIAL INTERROGATORY NO. 46: 12 For each SAFETY TRAINING that YOU identified in response to the Special 13 Interrogatory immediately preceding this one, indicate whether YOU did so while YOU were in 14 OSHA's "Severe Violator Enforcement Program" as a result of failing to adequately train 15 YOUR employees on safety processes. SPECIAL INTERROGATORY NO. 47: 17 For each occasion on which YOU contend YOU trained Plaintiff on safety processes, 18 indicate whether YOU infonned Plaintiff that YOU were in OSHA's "Severe Violator 19 Enforcement Program" as a result of failing to adequately train YOUR employees on safety 20 processes. 21 SPECIAL INTERROGATORY NO. 48: Describe all steps YOU took at any time in 2019 to evaluate modified work duties that 22 would accommodate PlaintifTs work restrictions. 23 PLAINTIFF SAnDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) SPECIAL INTERROGATORY NO. 49: For each particular injury that YOU contend Plaintiff failed to "immediately report", state 3 the date on which the injury was fu-st identified by any PERSON qualified to do so. 4 SPECIAL INTERROGATORY NO. 50; 5 Ofthe total days that YOUR packer employees missedfromwork over the past 5 years as 6 a resuh of injuries, what percentage was attributed to Cumulative Trauma injuries? 7 SPECIAL INTERROGATORY NO. 51: 8 Ofthe total days that YOUR operator employees missedfromwork over the past 5 years 9 as a result of injuries, what percentage was attributed to injuries other than Cumulative Trauma 10 injuries? SPECIAL INTERROGATORY NO. 52: II Please identify, by name, address and telephone number all PERSON(S) with personal 12 knowledge of YOUR contention that "all of the mega tote cart wheels were replaced three 13 months ago" as YOU claimed in YOUR "4 Panel EHS Disciplinary Review] that you produced 14 as LBC000062-63. 15 SPECIAL INTERROGATORY NO. 53; 16 Please identify, by date, source, location and custodian, all DOCUMENTS that RELATE 17 to YOUR contention that "all of the mega tote cart wheels were replaced three months ago" as IX YOU claimed in YOUR "4 Panel EHS Disciplmary Review" that you produced as 19 LBC000062-63. 20 // 21 // 22 // 23 PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) SPECIAL INTERROGATORY NO. 54; Please state all facts that support YOUR contention that "all of the mega tote cart wheels were replaced three months ago" as YOU claimed in YOUR "4 Panel EHS Disciplinary Review 4 that you produced as LBC000062-63." 5 SPECIAL INTERROGATORY NO. 55: 6 When YOU obtained Plaintiffs signed agreement to the CSB Policy in May 2018, did 7 YOU disclose to Plaintiff the fact that OSHA had cited and convicted YOU in March 2018 for 8 numerous serious and repeat violations of machine safety procedures? 9 SPECIAL INTERROGATORY NO. 56; Please state all facts that support YOUR contention, if YOU do so contend, that YOU 10 trained YOUR employees in the process of identifying a disease, condition, or injuryfromits signs and symptoms. SPECIAL INTERROGATORY NO. 57: 13 Please identify, by date, source, location and custodian, all DOCUMENTS that RELATE 14 to YOUR contention, if YOU do so contend, that YOU trained YOUR employees in the process 15 of identifying a disease, condition, or injuryfromits signs and symptoms. 16 SPECIAL INTERROGATORY NO. 58: 17 Please state all facts diat support YOUR contention, in YOUR "4 Panel EHS Disciplinary IX Review," which YOU produced as LBC000062-63, that Plaintiff "was diagnosed with a left knee 19 and hamstring sprain." 20 SPECIAL INTERROGATORY NO. 59: 21 Please identify, by date, source, location and custodian, all DOCUMENTS that RELATE 22 to YOUR contention, in YOUR "4 Panel EHS Disciplinary Review," which YOU produced as 23 LBC000062-63, that Plaintiff "was diagnosed with a left knee and hamstring sprain." PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) 1 SPECIAL INTERROGATORY NO. 60: Do YOU contend that Plaintiff's injuries were caused by Plaintiff's failure to follow any 3 instmctions YOU provided to Plaintiff infrainingher in the proper operation of a mega tote cart 4 (hereinafter, the "CART TRAINING(S)") ? 5 SPECIAL INTERROGATORY NO. 61; 6 Please state all facts that support YOUR contention that Plaintiffs injuries were caused 7 by Plaintiff's failure to follow any aspect ofthe CART TRAINING(S), if YOU do so contend. 8 SPECIAL INTERROGATORY NO. 62: 9 For each CART TRAINING that YOU claim YOU provided to Plaintiff, please indicate 10 whether attendance at the training was voluntaty or mandatory for Plaintiff. II SPECIAL INTERROGATORY NO. 63: For each CART TRAINING that YOU claim YOU provided to Plaintiff, please identify, 12 by name, address and telephone number all PERSON(S) who were present for any portion ofthe 13 training. 14 SPECIAL INTERROGATORY NO. 64: 15 For each CART TRAINING that YOU claim YOU provided to Plaintiff, please identify 16 all DOCUMENTS that reflect the matters presented, discussed, asked, or otherwise 17 communicated among any PERSON(S) at the training. IX SPECIAL INTERROGATORY NO. 65: 19 Please state all facts that support YOUR contention, if YOU do so contend, that 20 Plaintiffs actions leading to her injury were inconsistent with any of the CART TRAINING(S) 21 that YOU provided to her 22 23 PLAINTIFF SAHDA ZAMAN'S SPECL\L INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) Dated: May 27, 2022 FALAKASSA LAW, P.C. LIBERTY MAN LAW, P.C. 4 BY: 5 JOSHUA S. FALAKASSA 6 ARASH KHOSROWSHAHI Attomeys for Plaintiff SAJIDA ZAMAN 7 8 9 H) 11 12 13 14 15 16 17 IX 19 20 21 22 23 PLAINTIFF SAJIDA ZAMAN'S SPECIAL INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION (SET FOUR) 1 JOSHUA S. FALAKASSA fSBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 Los Angeles, Califomia 90067 3 Tel.:f818) 456-6168 Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 LIBERTY MAN LAW, P.C. 6 ARASH S. KHOSROWSHAHI (SBN: 293246) 1010 F Street, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469 8 Fax: (866) 700-0787 9 Email: ash@libertymanlaw.com 10 Attomeys for Plaintiff SAJIDA ZAMAN 11 12 SUPERIOR COURT OF CALIFORNIA 13 COUNTY OF SACRAMENTO 14 15 SAJIDA ZAMAN, an individual. CASE NO.: 34-2019-00252121 16 Plaintiff, DECLARATION OF ARASH KHOSROWSHAHI REGARDING THE vs. NEED FOR ADDITIONAL SPECIAL 17 INTERROGATORIES TO DEFENDANT LIQUI-BOX CORPORATION, and DOES 1 18 through 20, inclusive. [Served Concurrently with Plaintiffs Special 19 Interrogatories, Set Five] 20 Defendants. 21 22 23 24 25 26 27 28 1 DECLARATION OF ARASH KHOSROWSHAHI REGARDING THE NEED FOR ADDITIONAL SPECIAL INTERROGATORIES TO DEFENDANT 1 DECLARATION OF ARASH KHOSROWSHAHI 2 1, Arash Khosrowshahi, declare and state as follows: 3 1. 1 am presently the attomey for plaintiff Sajida Zaman ("Plaintiff'), a party to this 4 action. 5 2. I am propounding to defendant Liqui-Box Corporation ("Defendant") the attached 6 Special Interrogatories, Set Number Five (5). 7 3. This set of intenogatories will cause the total number of specially prepared 8 interrogatories propounded to the party to whom they are directed to exceed the number of 9 specially prepared mterrogatories permitted by Section 2030.030 of the Code of Civil Procedure. 10 4. 1 have previously propounded a total of thirty-three (42) specially prepared 11 interrogatories to this party. 12 5. This set of interrogatories contains a total of twenty-three (23) specially prepared 13 interrogatories. 14 6. I am familiar with the issues and the previous discovery conducted by all of the 15 parties to this case. 16 7. I have personally examined each of the questions in this set of interrogatories. 17 8. This number of questions is warranted under Section 2030.040 of the Code of Civil 18 Procedure because of the quantity and nature of the existing and potential issues involved, and the 19 expedience and benefit to each of the parties that will result in using this form of discovety to 20 obtain certain information about Defendant's positions, arguments and defenses. 21 9. None of the questions in this set of interrogatories is being propounded for any 22 improper purpose, such as to harass the party or the attomey for the party to whom it is directed or 23 to cause uimecessary delay or needless increase in the cost of litigation. 24 I declare under penalty of perjury under the laws of the State of Califomia that the 25 foregoing is tme and correct, and that this declaration was executed on May 27, 2022 at 26 Sacramento, Califomia. 27 Arash S. Khosrowshahi 28 DECLARATION OF ARASH KHOSROWSHAHI REGARDING THE NEED FOR ADDITIONAL SPECIAL INTERROGATORIES TO DEFENDANT