On June 09, 2020 a
Party Statement
was filed
involving a dispute between
Mobile Modular Portable Storage,
and
B&D Racing,
Schapiro Brian,
for Breach of Rental/Lease Contract (not unlawful detainer or wrongful eviction) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/26/2021 03:36 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Inloes,Deputy Clerk
1 TROUTMAN PEPPER HAMILTON SANDERS LLP
Jared D. Bissell, Bar No. 272687
2 jared.bissell@troutman.com
Tina Safi Felahi, Bar No. 300304
3 tina.felahi@troutman.com
11682 El Camino Real, Suite 400
4 San Diego, CA 92130-2092
Telephone: 858-509-6000
5 Facsimile: 858 509 6040
6 Attorneys for Plaintiff
MOBILE MODULAR PORTABLE STORAGE
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES
10
T ROUTMAN P EPPER H AMILTON S AN DERS LLP
11 MOBILE MODULAR PORTABLE Case No. 20VECV00634
STORAGE,
S A N D I E G O , C A 92130-2092
12 [Assigned for All Purposed to Hon. Theresa M.
11682 E L C A M I N O R E A L
Plaintiff, Traber, Dept. U]
S U I T E 400
13
v. DECLARATION OF TINA SAFI FELAHI
14 IN SUPPORT OF MOBILE MODULAR
B&D RACING; BRIAN SCHAPIRO; and PORTABLE STORAGE’S REQUEST FOR
15 DOES 1-10, inclusive, ENTRY OF JUDGMENT BY DEFAULT
AGAINST DEFENDANTS PURSUANT TO
16 Defendant. CALIFORNIA RULE OF COURT
3.1800(a)(1)
17
Complaint filed: June 9, 2020
18 Trial date: None set
19
20 I, Tina Safi Felahi, declare as follows:
21 1. I am an attorney at Troutman Pepper Hamilton Sanders LLP, attorneys for Plaintiff
22 Mobile Modular Portable Storage (“MMPS”) in the above-captioned action. If called upon to
23 testify as to the facts set forth herein, I could and would competently testify thereto because the
24 facts set forth herein are personally known to me.
25 2. This Declaration is made in support of Mobile Modular Portable Storage’s Request
26 for Judgment of Default against Defendant B&D Racing (“Defendant”) and to recover damages
27 after Defendant failed to make payments under a lease agreement and return the rented storage
28 containers.
114622564v1
DECLARATION OF TINA SAFI FELAHI IN SUPPORT OF REQUEST FOR ENTRY OF JUDGMENT BY
DEFAULT
Document Filed Date
March 26, 2021
Case Filing Date
June 09, 2020
Category
Breach of Rental/Lease Contract (not unlawful detainer or wrongful eviction) (General Jurisdiction)
Status
Default Judgment By Court - Before Trial 11/18/2022
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/26/2021 03:36 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Inloes,Deputy Clerk 1 TROUTMAN PEPPER HAMILTON SANDERS LLP Jared D. Bissell, Bar No. 272687 2 jared.bissell@troutman.com Tina Safi Felahi, Bar No. 300304 3 tina.felahi@troutman.com 11682 El Camino Real, Suite 400 4 San Diego, CA 92130-2092 Telephone: 858-509-6000 5 Facsimile: 858 509 6040 6 Attorneys for Plaintiff MOBILE MODULAR PORTABLE STORAGE 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 T ROUTMAN P EPPER H AMILTON S AN DERS LLP 11 MOBILE MODULAR PORTABLE Case No. 20VECV00634 STORAGE, S A N D I E G O , C A 92130-2092 12 [Assigned for All Purposed to Hon. Theresa M. 11682 E L C A M I N O R E A L Plaintiff, Traber, Dept. U] S U I T E 400 13 v. DECLARATION OF TINA SAFI FELAHI 14 IN SUPPORT OF MOBILE MODULAR B&D RACING; BRIAN SCHAPIRO; and PORTABLE STORAGE’S REQUEST FOR 15 DOES 1-10, inclusive, ENTRY OF JUDGMENT BY DEFAULT AGAINST DEFENDANTS PURSUANT TO 16 Defendant. CALIFORNIA RULE OF COURT 3.1800(a)(1) 17 Complaint filed: June 9, 2020 18 Trial date: None set 19 20 I, Tina Safi Felahi, declare as follows: 21 1. I am an attorney at Troutman Pepper Hamilton Sanders LLP, attorneys for Plaintiff 22 Mobile Modular Portable Storage (“MMPS”) in the above-captioned action. If called upon to 23 testify as to the facts set forth herein, I could and would competently testify thereto because the 24 facts set forth herein are personally known to me. 25 2. This Declaration is made in support of Mobile Modular Portable Storage’s Request 26 for Judgment of Default against Defendant B&D Racing (“Defendant”) and to recover damages 27 after Defendant failed to make payments under a lease agreement and return the rented storage 28 containers. 114622564v1 DECLARATION OF TINA SAFI FELAHI IN SUPPORT OF REQUEST FOR ENTRY OF JUDGMENT BY DEFAULT