On December 27, 2019 a
Motion-Secondary
was filed
involving a dispute between
Jung Thomas,
and
Bmw Of North America Llc,
Finchey Corporation Of California Dba Pacific Bmw,
for Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/16/2020 03:37 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
1 Adam M. Zolonz, S.B.N. 250591
Jeffrey A. Zolonz, S.B.N. 73285
2 Stephen Parnell, S.B.N. 314517
LAW OFFICES OF ADAM ZOLONZ, A.P.C.
3 1680 N. Vine Street, Suite 912
Los Angeles, California, 90028
4 Telephone: 310.247.8230
Facsimile: 310.888.1129
5
Attorneys for Plaintiff
6 THOMAS JUNG
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
10 FOR THE COUNTY OF LOS ANGELES
11 Case No. 19STCV46665
Law Offices of Adam Zolonz, A.P.C.
THOMAS JUNG, an individual,
1680 N. Vine Street, Suite 912
12 [Assigned for all Purposes to:
Los Angeles, CA 90028
Plaintiff, Hon. Robert S. Draper, Dept. 78]
13 v. DECLARATION OF STEPHEN
14 PARNELL IN SUPPORT OF
BMW OF NORTH AMERICA, LLC, a Delaware PLAINTIFF’S MOTION FOR
15 Limited Liability Company; FINCHEY ATTORNEYS’ FEES AND COSTS
CORPORATION OF CALIFORNIA, a California
16 Corporation d/b/a PACIFIC BMW; and DOES 1 [Notice and Motion; Memorandum of Points
through 20, inclusive, and Authorities; Declarations of Adam
17 Zolonz and Sherri Rangel; Exhibits;
Defendants. [Proposed] Order eFiled concurrently
18 herewith]
19
Reservation ID: 878368482681
20 Date: December 14, 2020
21 Action Filed: December 27, 2019
Trial Date: None
22
23 TO ALL PARTIES AND THEIR ATTORNEY OF RECORD:
24 I, Stephen Parnell, declare as follows:
25 1. I am an attorney at law duly licensed to practice before this Court, and if called upon
26 as a witness, I could testify based on my personal knowledge to the facts set forth below, except
27 where another basis for the assertion is specifically stated.
28 PLAINTIFF’S COUNSEL
Printed On
Recycled Paper
-1-
DECLARATION OF STEPHEN PARNELL IN SUPPORT OF PLAINTIFF’S MOTION FOR ATTORNEYS’
FEES AND COSTS
Document Filed Date
November 16, 2020
Case Filing Date
December 27, 2019
Category
Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 05/27/2020
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/16/2020 03:37 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk 1 Adam M. Zolonz, S.B.N. 250591 Jeffrey A. Zolonz, S.B.N. 73285 2 Stephen Parnell, S.B.N. 314517 LAW OFFICES OF ADAM ZOLONZ, A.P.C. 3 1680 N. Vine Street, Suite 912 Los Angeles, California, 90028 4 Telephone: 310.247.8230 Facsimile: 310.888.1129 5 Attorneys for Plaintiff 6 THOMAS JUNG 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 10 FOR THE COUNTY OF LOS ANGELES 11 Case No. 19STCV46665 Law Offices of Adam Zolonz, A.P.C. THOMAS JUNG, an individual, 1680 N. Vine Street, Suite 912 12 [Assigned for all Purposes to: Los Angeles, CA 90028 Plaintiff, Hon. Robert S. Draper, Dept. 78] 13 v. DECLARATION OF STEPHEN 14 PARNELL IN SUPPORT OF BMW OF NORTH AMERICA, LLC, a Delaware PLAINTIFF’S MOTION FOR 15 Limited Liability Company; FINCHEY ATTORNEYS’ FEES AND COSTS CORPORATION OF CALIFORNIA, a California 16 Corporation d/b/a PACIFIC BMW; and DOES 1 [Notice and Motion; Memorandum of Points through 20, inclusive, and Authorities; Declarations of Adam 17 Zolonz and Sherri Rangel; Exhibits; Defendants. [Proposed] Order eFiled concurrently 18 herewith] 19 Reservation ID: 878368482681 20 Date: December 14, 2020 21 Action Filed: December 27, 2019 Trial Date: None 22 23 TO ALL PARTIES AND THEIR ATTORNEY OF RECORD: 24 I, Stephen Parnell, declare as follows: 25 1. I am an attorney at law duly licensed to practice before this Court, and if called upon 26 as a witness, I could testify based on my personal knowledge to the facts set forth below, except 27 where another basis for the assertion is specifically stated. 28 PLAINTIFF’S COUNSEL Printed On Recycled Paper -1- DECLARATION OF STEPHEN PARNELL IN SUPPORT OF PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES AND COSTS