Party Statement: 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 02/03/2022 05:26 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. So,Deputy Clerk




                       1     MICHAEL W. VIVOLI (Bar No. 184366)
                             JASON P. SACCUZZO (Bar No. 221837)
                      2      mvivoli@vivolilaw.com
                             VIVOLI SACCUZZO, LLP
                       3     3104 Fourth Avenue
                             San Diego, California 92103
                       4     (619) 744-9992 (Tel)
                             (619) 744-9994 (Fax)
                       5
                             Attorneys for Plaintiff/Cross-Defendant,
                       6     SHAHRIAR SHOUHED
                       7
                       8                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
                       9                                IN AND FOR THE LOS ANGELES - CENTRAL DISTRICT
                     10
                             NATIONAL CAR WASHES, INC., a California ) CASE NO. 21STCV05032
                     11      corporation; and SHAHRIAR SHOUHED, an     ) [Case Assigned for All Purposes To: Hon.
                     12      individual,                               ) Kristin S. Escalante, Dept. 24]
                                                                       )
                     13                     Plaintiffs,                ) DECLARATION OF MICHAEL W.
                                                                       ) VIVOLI IN RESPONSE TO ORDER TO
                     14
                                   v.                                  ) SHOWCAUSE
                     15                                                )
                             SCOTT ALBERT ARDITI, an individual;       ) Date:     February 10, 2022
                     16      EXPERT CAR WASHES, INC., a California     ) Time: 8:30 a.m.
                             corporation, as a nominal defendant as to )
                     17
                             derivative claims; and DOES 1 through 50, ) Action Filed: February 8, 2021
                     18                                                ) Trial Date:    December 12, 2022
                                            Defendants.                )
                     19
                                                                                                            )
                     20
                             AND RELATED CROSS-ACTION.                                                      )
                     21
                     22
                     23                  I, MICHAEL W. VIVOLI, declare as follows:
                     24                  1.         I am an attorney duly licensed to practice law before all Courts of the State of
                     25      California and am a partner in the law firm of Vivoli Saccuzzo, LLP, attorneys of record for
                     26      Plaintiff/Cross-Defendant Shahriar Shouhed ("Mr. Shouhed").                                                As such, I have personal
                     27      knowledge of all facts contained herein and, if called upon to testify with respect thereto, I could
                     28      and would competently do so.


                                                                                                        I
                                                                  MICHAEL W. VIVOLI IN RESPONSE TO OSC RE: SANCTIONS