Motion-Secondary: LILIA MENDOZA MOGOLLON VS REZA SADEGHI, ET AL.

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                                DocuSign Envelope ID: D5374B90-E9BF-45B7-8A48-A036DD47C2A0

 Electronically FILED by Superior Court of California, County of Los Angeles on 03/26/2021 10:39 AM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




          1     DOUGLAS L. DAY, ESQ. – State Bar No. 92581
                STRATMAN, SCHWARTZ & WILLIAMS-ABREGO
          2     P.O. Box 258829
                Oklahoma City, OK 73125-8829
          3     Phone: (213) 615-2500
                Email: douglas.day@farmersinsurance.com
          4
                Attorney for Defendants,
          5     REZA SADEGHI, JANET SADEGHI, FAUSTO DURAN AND SUSANA DURAN
          6

          7

          8                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA
          9                                                FOR THE COUNTY OF LOS ANGELES
        10      LILIA MENDOZA MOGOLLON,                                                            Case No.: 20STCV38322
                                                                                                   UNLIMITED JURISDICTION
        11                             Plaintiff,
                                                                                                   ASSIGNED TO FOR ALL PURPOSES:
        12                  vs.                                                                    HON. WILLIAM F. FAHEY - DEPT. 69
                                                                                                   DEPT: 69
        13      REZA SADEGHI, AN INDIVIDUAL, JANET
                SADEGHI, AN INDIVIDUAL, DURAN FAUSTO, DECLARATION OF JANET SADEGHI IN
        14      AN INDIVIDUAL, SUSANA FAUSTO, AN      SUPPORT OF MOTION FOR PROTECTIVE
                INDIVIDUAL, DOES 1-100,               ORDER
        15
                                       Defendants.                                                 Date: May 25, 2021
        16                                                                                         Time: 9:30 a.m.
                                                                                                   Dept: 69
        17
                                                                                                   Reservation ID: 315520122518
        18

        19                  I, Janet Sadeghi, hereby declare as follows:
        20            1. I am a named defendant in this lawsuit along with my husband, Reza Sadeghi. In that capacity, I
        21                  am personally familiar with the facts set forth herein and if called as a witness in this case, I
        22                  could and would competently testify hereto.
        23            2. I am personally aware that my deposition has been noticed for April 1, 2021 at 1:00 p.m. at the
        24                  offices of Plaintiff’s counsel, located at 601 South Figueroa Street, Suite 2500, Los Angeles,
        25                  California, and my husband’s deposition has been noticed for April 1, 2021 at 10:00 a.m.
        26            3. Both notices call for the depositions to take place in person.
        27            4. I have no objection to having my deposition taken on April 1, 2021 since the date was agreed
        28                  upon.
                                                                       DECLARATION OF JANET SADEGHI
                                                               IN SUPPORT OF MOTION FOR PROTECTIVE ORDER - 1