On February 08, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Arditi Scott Albert,
Expert Car Washes Inc.,
National Car Washes Inc.,
Shouhed Shahriar,
and
Arditi Scott Albert,
Auto Care California Inc. A California Corporation As A Nominal Defendant As To Derivative Claims,
Expert Car Washes Inc.,
for Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
1 CURTIS A. GRAHAM (BAR NO. 89755)
curtis.graham@ffslaw.com
2 DAWN B. EYERLY (BAR NO. 185074)
dawn.eyerly@ffslaw.com
3 FREEMAN, FREEMAN & SMILEY, LLP
1888 Century Park East, Suite 1500
4 Los Angeles, California 90067
Telephone: (310) 255-6100
5 Facsimile: (310) 255-6200
6 Attorneys for Cross-Defendants SHAHRAM
SHOUHED and RAFIE SHOUHED
7 SPECIALLY APPEARING
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10 EXPERT CAR WASHES, INC., a California Case No. 21STCV05032
corporation; NATIONAL CAR WASHES,
11 INC., a California corporation; and STIPULATION AND [PROPOSED]
LLP
1888 CENTURY PARK EAST, SUITE 1500
SHAHRIAR SHOUHED, an individual, ORDER FOR ADDITIONAL TIME TO
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
12 FILE DEMURRER TO CROSS-
Plaintiffs, COMPLAINT
13
(310) 255-6100
vs. Assigned for All Purposes to the Hon.
Electronically Received 09/12/2022 03:01 PM
14 Krisitin S. Escalante, Dept. 24
SCOTT ALBERT ARDITI, an individual;
15 EXPERT CAR WASHES, INC., a California Action Filed: February 8, 2021
corporation, as a nominal defendant as to Trial Date: December 12, 2022
16 derivative claims, and DOES 1 through 50,
17
Defendants.
18
AND RELATED CROSS-ACTION
19
20 STIPULATION
21 Cross-Complainant, Albert Scott Arditi and Cross-Defendants, Shahram Shouhed and
22 Rafie Shouhed, Specially Appearing, stipulate as follows:
23 1. Cross-Defendants filed a Declaration of Demurring Party in Support of Automatic
24 Extension on August 12, 2022; the new deadline for filing a demurrer is September 12, 2022.
25 2. The Parties, including through other counsel, have been able to spend some time
26 meeting and conferring in good faith.
27 3. However, due to the length of the Cross-Complaint (13 causes of action) and some
28 of the issues involved, counsel have not been able to complete the process.
5524193.1 24594-805
STIPULATION AND [PROPOSED] ORDER FOR ADDITIONAL TIME
TO FILE DEMURRER TO CROSS-COMPLAINT
Document Filed Date
September 14, 2022
Case Filing Date
February 08, 2021
Category
Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
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Preview
1 CURTIS A. GRAHAM (BAR NO. 89755) curtis.graham@ffslaw.com 2 DAWN B. EYERLY (BAR NO. 185074) dawn.eyerly@ffslaw.com 3 FREEMAN, FREEMAN & SMILEY, LLP 1888 Century Park East, Suite 1500 4 Los Angeles, California 90067 Telephone: (310) 255-6100 5 Facsimile: (310) 255-6200 6 Attorneys for Cross-Defendants SHAHRAM SHOUHED and RAFIE SHOUHED 7 SPECIALLY APPEARING 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 EXPERT CAR WASHES, INC., a California Case No. 21STCV05032 corporation; NATIONAL CAR WASHES, 11 INC., a California corporation; and STIPULATION AND [PROPOSED] LLP 1888 CENTURY PARK EAST, SUITE 1500 SHAHRIAR SHOUHED, an individual, ORDER FOR ADDITIONAL TIME TO LOS ANGELES, CALIFORNIA 90067 FREEMAN, FREEMAN & SMILEY, 12 FILE DEMURRER TO CROSS- Plaintiffs, COMPLAINT 13 (310) 255-6100 vs. Assigned for All Purposes to the Hon. Electronically Received 09/12/2022 03:01 PM 14 Krisitin S. Escalante, Dept. 24 SCOTT ALBERT ARDITI, an individual; 15 EXPERT CAR WASHES, INC., a California Action Filed: February 8, 2021 corporation, as a nominal defendant as to Trial Date: December 12, 2022 16 derivative claims, and DOES 1 through 50, 17 Defendants. 18 AND RELATED CROSS-ACTION 19 20 STIPULATION 21 Cross-Complainant, Albert Scott Arditi and Cross-Defendants, Shahram Shouhed and 22 Rafie Shouhed, Specially Appearing, stipulate as follows: 23 1. Cross-Defendants filed a Declaration of Demurring Party in Support of Automatic 24 Extension on August 12, 2022; the new deadline for filing a demurrer is September 12, 2022. 25 2. The Parties, including through other counsel, have been able to spend some time 26 meeting and conferring in good faith. 27 3. However, due to the length of the Cross-Complaint (13 causes of action) and some 28 of the issues involved, counsel have not been able to complete the process. 5524193.1 24594-805 STIPULATION AND [PROPOSED] ORDER FOR ADDITIONAL TIME TO FILE DEMURRER TO CROSS-COMPLAINT