Motion-Secondary: JAFAR ROUHBAKHSHYENGEJEH VS BEATRICE MONTANEZ

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/16/2022 10:41 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Trinh,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,                                               DECLARATION OF JONATHAN D.
                                                                                                     BOBAK, ESQ. IN SUPPORT OF
             13                  v.                                                                  DEFENDANT BEATRICE
                                                                                                     MONTANEZ’S MOTION IN LIMINE TO
             14                                                                                      PRECLUDE QUESTIONING
                      BEATRICE MONTANEZ,                                                             PROSPECTIVE JURORS ABOUT, OR
             15                                                                                      OTHERWISE MENTIONING, DOLLAR
                                            Defendant.                                               AMOUNTS AS POTENTIAL DAMAGES
             16
                                                                                                     [MIL No. 3 of 11]
             17
                                                                                                     FSC Date:                    September 22, 2022
             18                                                                                      Time:                        10:00 a.m.
                                                                                                     Dept.:                       30
             19                                                                                      Judge:                       Hon. Jill T. Feeney

             20                                                                                      Action Filed:                August 23, 2019
                      AND RELATED CROSS-ACTION.                                                      Trial Date:                  October 7, 2022
             21

             22

             23                  I, Jonathan D. Bobak, Esq., declare as follows:

             24                  1.         I am an attorney at law, duly licensed to practice law in all courts of the State of

             25      California, and am an associate with the law firm NOON & ASSOCIATES, PC, attorneys of record

             26      for Defendant BEATRICE MONTANEZ. I am fully familiar with the facts and circumstances in the

             27      above-entitled matter as they relate to this Declaration and if called upon, I could and would

             28      competently testify thereto.
                                                                  1
                        DECLARATION OF JONATHAN D. BOBAK, ESQ. IN SUPPORT OF DEFENDANT BEATRICE MONTANEZ’S
                         MOTION IN LIMINE TO PRECLUDE QUESTIONING PROSPECTIVE JURORS ABOUT, OR OTHERWISE
                                        MENTIONING, DOLLAR AMOUNTS AS POTENTIAL DAMAGES