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

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                                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 DOUGLAS L. DAY 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, DOUGLAS L. DAY, declare:
       20                  1.         I am an attorney at law, duly licensed to practice in all Courts of the State of California,
       21                  and am a member of the law offices of STRATMAN, SCHWARTZ & WILLIAMS-ABREGO,
       22                  attorneys of record for Defendants, REZA SADEGHI, JANET SADEGHI, FAUSTO DURAN
       23                  AND SUSANA DURAN, in the above-entitled matter.                                               I am an employee of the Claims
       24                  Litigation Department, Farmers Insurance Exchange and Affiliates, Not a Partnership.
       25                  2.         I am the attorney assigned with the responsibility for the file on this matter, and have
       26                  thoroughly reviewed its contents and am personally familiar with each of the facts set forth
       27                  herein. If called as a witness, I could and would competently testify hereto.
       28

                                                                         DECLARATION OF DOUGLAS L. DAY
                                                               IN SUPPORT OF MOTION FOR PROTECTIVE ORDER - 1