Party Discovery: JOSHUA FAKHRI VS JUSTOURS, INC., A DELAWARE CORPORATION, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 08/04/2021 04:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,Deputy Clerk




                             1   BUCHALTER
                                 A Professional Corporation
                             2   JOSHUA MIZRAHI (SBN: 227639)
                                 WILLIAM S. LISA (SBN: 310541)
                             3   1000 Wilshire Boulevard, Suite 1500
                                 Los Angeles, CA 90017-1730
                             4   Telephone: 213.891.0700
                                 Fax: 213.896.0400
                             5   Email: jmizrahi@buchalter.com
                                        wlisa@buchalter.com
                             6
                                 Attorneys for Defendant
                             7   JUSTOURS, INC.

                             8
                                                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
                             9
                                                 FOR THE COUNTY OF LOS ANGELES – CENTRAL DISTRICT
                        10

                        11       JOSHUA FAKHRI, an individual,                                               CASE NO. 20STCV38636
                        12                       Plaintiff,                                                  Assigned to the Hon. Michael L. Stern
                                                                                                             Dept. No. 62
                        13               v.
                                                                                                             DEFENDANT JUSTOURS, INC.’S
                        14       JUSTOURS, INC., a Delaware corporation;                                     REPLY MEMORANDUM IN SUPPORT
                                 STREETTEAM SOFTWARE LLC, a Delaware                                         OF MOTION TO COMPEL FURTHER
                        15       corporation; and DOES 1 through 50, inclusive,                              RESPONSES TO REQUESTS FOR
                                                                                                             PRODUCTION
                        16                       Defendants.
                        17                                                                                   Date: August 10, 2021
                                                                                                             Time: 9:00 a.m.
                        18                                                                                   Dept.: 62
                                                                                                             Reservation ID: 726570502530
                        19

                        20                                                      REPLY MEMORANDUM

                        21       I.      INTRODUCTION

                        22               As set forth in Defendant JusTours, Inc.’s moving papers, Defendant attempted to meet and

                        23       confer with Plaintiff’s counsel in good faith concerning Plaintiff’s deficient discovery responses,

                        24       sending multiple emails and calling multiple times in an endeavor to avoid unnecessary motion

                        25       practice, up to and including the afternoon the motion was filed. Plaintiff responded to only one

                        26       email, in which he advised that he was open to further meet and confer efforts. Notwithstanding

                        27       this representation, Plaintiff declined to respond to subsequent emails or telephone calls, preferring

                        28       instead to resolve the issue by way of motion practice. Plaintiff’s discovery responses and document
     BUCHALTER
A PROFESSIONAL CORPORATION
                                 BN 46471101V1                                                      1
       LOS ANGELES
                                      DEFENDANT JUSTOURS, INC.’S REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL
                                      FURTHER RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, AND SANCTIONS;
                                                                   CASE NO. 20STCV38636