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1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450
3 Los Angeles, Califomia 90067
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
Fi LEO/EiOQmi EO
5 ARASH S. KHOSROWSHAHI (SBN: 293246) AUG - 3 2022
6 LIBERTY MAN LAW, P.C.
1010 F Street, Ste. 300 By:. H. PEMFI TON
Deputy Clerk
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO
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SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
14 RESERVATION ID; 2664199
Plaintiff,
15 NOTICE OF MOTION AND MOTION
vs. TO COMPEL FURTHER RESPONSES
16 TO PLAINTIFF SAJIDA ZAMAN'S
LIQUI-BOX CORPORATION, and DOES 1 SPECIAL INTERROGATORIES, SET
17 through 20, inclusive, FOUR, AND MONETARY SANCTIONS
18 Defendants.
Date: October 18, 2022 BY FAX
19 Time: 1:30pm
Dept.: 53
20 Trial Date: September 12, 2022
21
22 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
23 NOTICE IS HEREBY GIVEN tiiat on October 18, 2022 at 1:30p.m., or as soon tiiereaftei
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 move for an order compelling Defendant Liqui-Box Corporation ("Defendant") to provide further
27 responses to Plaintiffs Special Intenogatories to Defendant Liqui-Box Corporation, Set Four,
28 which Plaintiff served on Defendant on or about May 24, 2022, and will further move this court
NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF SAJIDA
ZAMAN'S SPECL\L INTERROGATORIES, SET FOUR, AND MONETARY SANCTIONS
lof 2
1 for an order requiring Defendant to pay monetaty sanctions in the amount of $3,160.00 to Plaintiff
2 (Code Civ. Proc. §§ 2023.010(e), (i); 2023.020; 2023.030(a); 2030.300(d).) The motion will be
3 made on the grounds that Defendant has made objections which are without merit and/or too
4 general without substantial justification {Id. § 2030.300(a)(3)); and should therefore be sanctioned
5 for (1) making meritless objections to discovety, and (2) failing to meet and confer in a reasonable
6 and good faith attempt to resolve informally the herein discovety disputes. {Id., § 2023.010(e), (i).)
7 The motion will be based on this Notice, Separate Statement, Declaration of Arash S
8 Khosrowshahi, the Memorandum of Points and Authorities, on the records and file herein, and on
9 such evidence as may be presented at the hearing of the motion.
10 Dated: August 2, 2022 LIBERTY MAN LAW, P.C.
11 FALAKASSA LAW, P.C.
12
13 Arash S. Khosrowshahi
14 Joshua S. Falakassa
Attomeys for Plaintiff Sajida Zaman
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NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF SAJIDA
ZAMAN'S SPECL\L INTERROGATORIES, SET FOUR, AND MONETARY SANCTIONS
2 of 2
1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450
3 Los Angeles, Califomia 90067
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
6 LIBERTY 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 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO
13
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
14 RESERVATION ID; 2664199
Plaintiff, [PROPOSED] ORDER GRANTING
15 MOTION TO COMPEL FURTHER
RESPONSES TO PLAINTIFF SAJIDA
16 vs. ZAMAN'S SPECIAL
INTERROGATORIES, SET FOUR, AND
17 LIQUI-BOX CORPORATION, and DOES 1 MONETARY SANCTIONS
through 20, inclusive.
18
Date: October 18, 2022
Defendants. Time: 1:30pm
19
Dept.: 53
20 Trial Date: September 12, 2022
21 Plaintiff Sajida Zaman's ("Plaintiff') Motion to Compel Further Responses as to Special
22 Interrogatories, Set Four, and Monetaty Sanctions ("Motion to Compel") was regularly heard at
23 the above date and time. Arash S. Khosrowshahi, Esq. appeared on behalf of Plaintiff; James T
24 Jones, Esq. appeared on behalf of Defendant Liqui-Box Corporation ("Defendant").
25 Satisfactoty proof having been made, and good cause appearing, IT IS ORDERED that:
26
[PROPOSED] ORDER
1 of 2
1 1. Plaintiffs Motion to Compel is GRANTED as to Special Interrogatories, Set 4
2 Defendant is ordered to provide responses in compliance with the Civil Discovery Act
3 within five days of this Order;
4 2. Sanctions in the form of reasonable attorneys' fees be ordered against Defendant in the
5 amount of $3,160.00 for the hours Plaintiffs counsel has expended in researching and
6 drafting the Motion to Compel, as well as for Plaintiffs incurred filing costs, payable
7 within five days of this Order;
8 3. Any other relief the Court deems proper.
9 Date:
10
^^ Judge of the Superior Court
22 County of Sacramento
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[PROPOSED] ORDER
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1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 3 Los Angeles, Califomia 90067 Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com Fi LEO/EiOQmi EO 5 ARASH S. KHOSROWSHAHI (SBN: 293246) AUG - 3 2022 6 LIBERTY MAN LAW, P.C. 1010 F Street, Ste. 300 By:. H. PEMFI TON Deputy Clerk 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 14 RESERVATION ID; 2664199 Plaintiff, 15 NOTICE OF MOTION AND MOTION vs. TO COMPEL FURTHER RESPONSES 16 TO PLAINTIFF SAJIDA ZAMAN'S LIQUI-BOX CORPORATION, and DOES 1 SPECIAL INTERROGATORIES, SET 17 through 20, inclusive, FOUR, AND MONETARY SANCTIONS 18 Defendants. Date: October 18, 2022 BY FAX 19 Time: 1:30pm Dept.: 53 20 Trial Date: September 12, 2022 21 22 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 23 NOTICE IS HEREBY GIVEN tiiat on October 18, 2022 at 1:30p.m., or as soon tiiereaftei 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 move for an order compelling Defendant Liqui-Box Corporation ("Defendant") to provide further 27 responses to Plaintiffs Special Intenogatories to Defendant Liqui-Box Corporation, Set Four, 28 which Plaintiff served on Defendant on or about May 24, 2022, and will further move this court NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES, SET FOUR, AND MONETARY SANCTIONS lof 2 1 for an order requiring Defendant to pay monetaty sanctions in the amount of $3,160.00 to Plaintiff 2 (Code Civ. Proc. §§ 2023.010(e), (i); 2023.020; 2023.030(a); 2030.300(d).) The motion will be 3 made on the grounds that Defendant has made objections which are without merit and/or too 4 general without substantial justification {Id. § 2030.300(a)(3)); and should therefore be sanctioned 5 for (1) making meritless objections to discovety, and (2) failing to meet and confer in a reasonable 6 and good faith attempt to resolve informally the herein discovety disputes. {Id., § 2023.010(e), (i).) 7 The motion will be based on this Notice, Separate Statement, Declaration of Arash S 8 Khosrowshahi, the Memorandum of Points and Authorities, on the records and file herein, and on 9 such evidence as may be presented at the hearing of the motion. 10 Dated: August 2, 2022 LIBERTY MAN LAW, P.C. 11 FALAKASSA LAW, P.C. 12 13 Arash S. Khosrowshahi 14 Joshua S. Falakassa Attomeys for Plaintiff Sajida Zaman 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF SAJIDA ZAMAN'S SPECL\L INTERROGATORIES, SET FOUR, AND MONETARY SANCTIONS 2 of 2 1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 3 Los Angeles, Califomia 90067 Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 ARASH S. KHOSROWSHAHI (SBN: 293246) 6 LIBERTY 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 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 14 RESERVATION ID; 2664199 Plaintiff, [PROPOSED] ORDER GRANTING 15 MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF SAJIDA 16 vs. ZAMAN'S SPECIAL INTERROGATORIES, SET FOUR, AND 17 LIQUI-BOX CORPORATION, and DOES 1 MONETARY SANCTIONS through 20, inclusive. 18 Date: October 18, 2022 Defendants. Time: 1:30pm 19 Dept.: 53 20 Trial Date: September 12, 2022 21 Plaintiff Sajida Zaman's ("Plaintiff') Motion to Compel Further Responses as to Special 22 Interrogatories, Set Four, and Monetaty Sanctions ("Motion to Compel") was regularly heard at 23 the above date and time. Arash S. Khosrowshahi, Esq. appeared on behalf of Plaintiff; James T 24 Jones, Esq. appeared on behalf of Defendant Liqui-Box Corporation ("Defendant"). 25 Satisfactoty proof having been made, and good cause appearing, IT IS ORDERED that: 26 [PROPOSED] ORDER 1 of 2 1 1. Plaintiffs Motion to Compel is GRANTED as to Special Interrogatories, Set 4 2 Defendant is ordered to provide responses in compliance with the Civil Discovery Act 3 within five days of this Order; 4 2. Sanctions in the form of reasonable attorneys' fees be ordered against Defendant in the 5 amount of $3,160.00 for the hours Plaintiffs counsel has expended in researching and 6 drafting the Motion to Compel, as well as for Plaintiffs incurred filing costs, payable 7 within five days of this Order; 8 3. Any other relief the Court deems proper. 9 Date: 10 ^^ Judge of the Superior Court 22 County of Sacramento 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [PROPOSED] ORDER 2 of 2