On February 08, 2021 a
Motion-Secondary
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
Electronically FILED by Superior Court of California, County of Los Angeles on 09/29/2021 03:12 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
1 MICHAEL W. VIVOLI (Bar No. 184366)
JASON P. SACCUZZO (Bar No. 221837)
2 mvivoli@vivolilaw.com
VIVOLISACCUZZO,LLP
3 3104 Fourth Avenue
San Diego, California 92103
4 (619) 744-9992 (Tel)
(619) 744-9994 (Fax)
5
Attorneys for Plaintiffs,
6 NATIONAL CAR WASHES, INC.
7 and SHAHRIAR SHOUHED
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE LOS ANGELES - CENTRAL DISTRICT
10
11 NATIONAL CAR WASHES, INC., a California ) CASE NO. 21STCV05032
12 corporation; and SHAHRIAR SHOUHED, an ) [Case Assigned for All Purposes To: Hon.
individual, ) Kristin S. Escalante, Dept. 24]
13 )
Plaintiffs, ) PLAINTIFFS' MEMORANDUM OF
14 ) POINTS & AUTHORITIES IN SUPPORT
15 V. ) OF OPPOSITION TO MOTION TO
) DISQUALIFY VIVOLI SACCUZZO,
16 SCOTT ALBERT ARDITI, an individual; ) LLP; DECLARATION OF MICHAEL W.
17 EXPERT CAR WASHES, INC., a California ) VIVOLI & ATTACHED EXHIBITS IN
corporation, as a nominal defendant as to ) SUPPORT THEREOF
18 derivative claims, and DOES 1 through 50, )
Defendants. ) Date: October 13, 2021
19 ) Time: 8:30 a.m.
) RESERVATION ID: 807377127561
20
)
21 ) Action Filed: February 8, 2021
----------------
22 Plaintiffs, National Car Washes, Inc. ("National") and Shahriar Shouhed ("Mr. Shouhed")
23 (collectively, "Plaintiffs"), respectfully submit the following memorandum of points and
24 authorities in opposition to the motion by Defendant/Cross-Complainant Albert Scott Arditi
25 ("Arditi") to disqualify Vivoli Saccuzzo, LLP from representing Plaintiffs and now nominal
26 defendant Expert Car Washes, Inc. ("Expert") in this action:
27 II//
28 / / //
PLAINTIFFS' OPPOSITION TO MOTION TO DISQUALIFY VIVOLI SACCUZZO, LLP
Document Filed Date
September 29, 2021
Case Filing Date
February 08, 2021
Category
Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
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