On August 23, 2019 a
Complaint,Petition
was filed
involving a dispute between
Montanez Beatrice,
Rouhbakhshyengejeh Jafar,
and
Montanez Beatrice,
for Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/16/2022 11:25 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Reyes,Deputy Clerk
1 TIMOTHY S. NOON, ESQ. (SBN 166193)
tnoon@noonlaw.com
2 JONATHAN D. BOBAK, ESQ. (SBN 312374)
jbobak@noonlaw.com
3 NOON & ASSOCIATES, PC
600 West Broadway, Suite 1550
4 San Diego, California 92101
Telephone: (619) 614-1800
5
Attorneys for Defendant/Cross-Complainant
6 BEATRICE MONTANEZ
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
10 SPRING STREET COURTHOUSE
11 JAFAR ROUHBAKHYENGEJEH, Case No. 19STCV30292
12 Plaintiff, PROOF OF SERVICE
13 v.
14
BEATRICE MONTANEZ,
15 Dept.: 30
Defendant. Judge: Hon. Jill T. Feeney
16
Action Filed: August 23, 2019
17 AND RELATED CROSS-ACTION. Trial Date: October 7, 2022
18
19 I, the undersigned, declare:
20 I am a resident of the State of California and over the age of eighteen years, and not a party
to the within-entitled action; my business address is 600 West Broadway, Suite 1550, San Diego,
21 California 92101. On September 16, 2022, I served the following documents, with all exhibits (if
any):
22
DEFENDANT BEATRICE MONTANEZ’S MOTION IN LIMINE TO EXCLUDE
23 IMPERMISSIBLE ARGUMENT AND REFERENCES, SUCH AS GOLDEN RULE,
REPTILE THEORY AND PLAINTIFF AS VICTIM AND OTHER IMPERMISSIBLE
24 CONDUCT [MIL No. 1 of 11]
25 DECLARATION OF JONATHAN D. BOBAK, ESQ. IN SUPPORT [MIL No. 1 of 11]
26 DEFENDANT BEATRICE MONTANEZ’S MOTION IN LIMINE TO EXCLUDE
PLAINTIFF’S PAST AND FUTURE EXPENSES AS BILLED [MIL No. 2 of 11]
27
DECLARATION OF JONATHAN D. BOBAK, ESQ. IN SUPPORT [MIL No. 2 of 11]
28
1
PROOF OF SERVICE
Document Filed Date
September 16, 2022
Case Filing Date
August 23, 2019
Category
Personal Injury/Property Damage/Wrongful Death - Uninsured Motorist (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 01/24/2023
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/16/2022 11:25 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Reyes,Deputy Clerk 1 TIMOTHY S. NOON, ESQ. (SBN 166193) tnoon@noonlaw.com 2 JONATHAN D. BOBAK, ESQ. (SBN 312374) jbobak@noonlaw.com 3 NOON & ASSOCIATES, PC 600 West Broadway, Suite 1550 4 San Diego, California 92101 Telephone: (619) 614-1800 5 Attorneys for Defendant/Cross-Complainant 6 BEATRICE MONTANEZ 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 SPRING STREET COURTHOUSE 11 JAFAR ROUHBAKHYENGEJEH, Case No. 19STCV30292 12 Plaintiff, PROOF OF SERVICE 13 v. 14 BEATRICE MONTANEZ, 15 Dept.: 30 Defendant. Judge: Hon. Jill T. Feeney 16 Action Filed: August 23, 2019 17 AND RELATED CROSS-ACTION. Trial Date: October 7, 2022 18 19 I, the undersigned, declare: 20 I am a resident of the State of California and over the age of eighteen years, and not a party to the within-entitled action; my business address is 600 West Broadway, Suite 1550, San Diego, 21 California 92101. On September 16, 2022, I served the following documents, with all exhibits (if any): 22 DEFENDANT BEATRICE MONTANEZ’S MOTION IN LIMINE TO EXCLUDE 23 IMPERMISSIBLE ARGUMENT AND REFERENCES, SUCH AS GOLDEN RULE, REPTILE THEORY AND PLAINTIFF AS VICTIM AND OTHER IMPERMISSIBLE 24 CONDUCT [MIL No. 1 of 11] 25 DECLARATION OF JONATHAN D. BOBAK, ESQ. IN SUPPORT [MIL No. 1 of 11] 26 DEFENDANT BEATRICE MONTANEZ’S MOTION IN LIMINE TO EXCLUDE PLAINTIFF’S PAST AND FUTURE EXPENSES AS BILLED [MIL No. 2 of 11] 27 DECLARATION OF JONATHAN D. BOBAK, ESQ. IN SUPPORT [MIL No. 2 of 11] 28 1 PROOF OF SERVICE