Motion,Ex Parte: ABOLFAZL RAHBAR VAFAEE VS RAJAN ALAGH, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 05/19/2021 03:26 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                  I       LAW OFFICES OF GREGORY J. LUCETT
                          330 North Brand Blvd., Suite 900
                 2        Glendale,CA 91203-2340
                          Telephone: (818) 548-6349
                 J        By: GILLIAN MELLON
                          Siate Bar No. 300830
                  A
                 .+
                          Our File No. 0459247458.2-BCD
                  5       Attorneys for Defendants :
                          RAJAN ALAGH ANd CRP ALAGH CORP. INC.
                  6

                  1



                  8                                  SUPEzuOR COURT OF THE STATE OF CALIFORNIA

                  9                        COUNTY OF LOS ANGELES - CENTRAL DISTRICT .I.INLIMITED

                10

                 l1         ABOLFAZL RAHBAR VAFAEE"                                              CASENO. 19STCV19523

                 t2
                                                                                                 NOTICE OF MOTION AND MOTION
                                   Plaintiff,                                                    FOR ORDER COMPELLING
                 l3                                                                              PLAINTIFF TO RESPOND TO
                             VS.
                                                                                                 REQUEST FOR PRODUCTION OF
                                                                                                 DOCTJMBNTS, SET ONE AND
                 l4          RAJAN ALAGH, CRP ALAGH                                              REQ{JEST FOR SANCTIONS AGAINST
                             CORP. INC., SUBWAY SANDWICH                                         PLAINTIFF AND/OR PLAINTIFF'S
                 l5          SHOPS INC., THREE SONS & A                                          COUNSEL OF RECORD IN THE
                             DOG INC. and DOES l-25,                                             AMOUNT OF $461.6s; MEMORANDUM
                 t6                                                                              OF POINTS AND AUTHORITIES;
                                   Defendants.                                                   DECLARATION OF GILLIAN;
                 t7
                                                                                                 MELLON; AND [PROPOSEDI ORDER
                 l8                                                                               Date:          June 29,2021
                 19
                                                                                                  Time:         08:30 a.m.
                                                                                                  Judse:        Hon.
                 20
                                                                                                  Dep-t.:        27

                                                                                                  Reservation lD : 92          417 41   83454
                 21

                 22

                 LJ       TO ALL PARTIES AND ATTORNEYS OF RECORD:

                 24                   NOTICE IS HBREBY GIVEN, that on                              June 29, 2021, at 08:30 a.m.,               in Department 27,

                 25       or as soon thereafter as the matter be heard in SUPERIOR COURT OF CALIFORNIA, COUNTY

                 26       OF LOS ANGELES, located at3l2 North Spring Street, Los Angeles, CA, Defendant, RAJAN

                 27       ALAGH and CRP ALAGH CORP. INC., (hereinafter "Defendant"), will move the Court for                                                           an


                 28       order compelling Plaintiff, ABOLFAZL RAHBAR VAFAEE (hereinafter "Plaintiff'). to serve
                                                                 I
                           MOTION FOR ORDER COMPELLING  PLAINTIFF  TO RESPOND TO REQUEST FOR PRODUCTION OF
                                DOCUMENTS, SET ONE AND REQUEST FOR SANCTIONS AGAINST PLAINTIFF AND/OR
                                        PLAINTIFF'S COUNSEL OF RECORD IN THE AMOUNT OF $46I.65