Motion-Secondary: EXPERT CAR WASHES, INC., ET AL. VS SCOTT ALBERT ARDITI

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/09/2023 03:00 PM David W. Slayton, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk



                                                                                                                                                                           CIV-141
           ATTORNEY OR PARTY WITHOUT ATTORNEY                              STATE BAR NO:   89755 / 185074                                     FOR COURT USE ONLY
           NAME:  Curtis A. Graham / Dawn B. Eyerly
           FIRM NAME: FREEMAN, FREEMAN & SMILEY, LLP
           STREET ADDRESS: 1888 Century Park East, Suite 1500
           CITY: Los Angeles                               STATE: CA      ZIP CODE: 90067
           TELEPHONE NO.: 310-255-6100                    FAX NO.: 310-255-6200
           E-MAIL ADDRESS: curtis.graham@ffslaw.com / dawn.eyerly@ffslaw.com
           ATTORNEY FOR (Name): Cross-Defendants Rafie Shouhed and Shahram Shouhed

           SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS        ANGELES
            STREET ADDRESS:    111 N. Hill Street
            MAILING ADDRESS: 111 N. Hill Street
            CITY AND ZIP CODE: Los Angeles, CA 90012
               BRANCH NAME: Central District (Stanley Mosk Courthouse)

              PLAINTIFF/PETITIONER: NATIONAL CAR WASHES, INC.,                                et al.
           DEFENDANT/RESPONDENT: SCOTT ALBERT ARDITI, et al.

                                                                                                                             CASE NUMBER:
                              DECLARATION OF DEMURRING OR MOVING PARTY                                                       21STCV05032
                                  IN SUPPORT OF AUTOMATIC EXTENSION

          1. (Name of party): Rafie Shouhed and Shahram Shouhed                                                               was served with

                      a complaint                  an amended complaint                           an amended cross-complaint
                      an answer                    other (specify):
              in the above-titled action.
          2. For a demurrer or motion to strike, a responsive pleading is due on (date): March 10, 2023

                                                                           DECLARATION
           I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to
           meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive
           pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
           pleadings may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not
           previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the
           requirements of Code of Civil Procedure sections 430.41, 435.5, or 439, I am entitled to an automatic 30-day extension of time within
           which to file a responsive pleading or motion for judgment on the pleadings.
           I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive
           pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
           pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because
           (the reasons why the parties could not meet and confer are stated):
                           below                  on form MC-031, Attached Declaration
          Cross-complainant's counsel has been unable to meet and confer. The parties are still in settlement talks with the
          parties' appointed mediator.




                   I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
                   Date: March 9, 2023

                                       Curtis A. Graham                                                
                                      (NAME OF PARTY OR ATTORNEY FOR PARTY)                                 (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)
                                                                                                           Rafie Shouhed and Shahram Shouhed
                                                                                                                                                                             Page 1 of 1
          Form Approved for Optional Use                                                                                                                         Code of Civil Procedure,
          Judicial Council of California
                                                         DECLARATION OF DEMURRING OR MOVING PARTY                                                                  §§ 430.41, 435.5, 439
          CIV-141 [Rev. January 1, 2019]                     IN SUPPORT OF AUTOMATIC EXTENSION                                                                        www.courts.ca.gov

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          5716399.1 / 24594-805