Party Statement: MATTHEW KOHUT VS ARASH FAYZ, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/17/2019 01:16 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




                1     JONATHAN J. DELSHAD, SBN 246176
                      jdelshad@delshadlegal.com
                2     ELIE D. GHODSIZADEH, SBN 297961
                3     eghodsi@delshadlegal.com
                      LAW OFFICES OF JONATHAN J. DELSHAD, PC
                4     1663 Sawtelle Blvd., Suite 220
                      Los Angeles, CA 90025
                5     Telephone:      424.255.8376
                      Fax:            424.256.7899
                6     Attorneys for Plaintiffs
                7
                                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA
                8
                                                                        COUNTY OF LOS ANGELES
                9

              10        Matthew Kohut, on behalf of himself and all                              ))    Case No.: 19STCV20606
                        others similarly situated,                                               ))
              11                                                                                 ))    DECLARATION OF JONATHAN J.
                                 Plaintiffs,                                                     ))    DELSHAD
              12                                                                                 ))
              13                 v.                                                              ))
                                                                                                 ))    Date: October 9, 2019
              14        LA Tutors 123, a California Corporation,                                 ))    Time: 8:30AM
                        Arash Fayz, an individual, and DOES 1-10,                                ))    Dept.: 32
              15        inclusive,                                                               ))    Judge: Hon. Daniel S. Murphy
                                                                                                 ))
              16                                                                                 ))
                                Defendants.
              17                                                                                 ))

              18                   I, Jonathan J. Delshad, the Declarant Depose and state:

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

              20        California and attorneys of record for the Plaintiff herein. I have personal knowledge of the facts

              21        set forth herein, except for those matters stated upon information and belief and, as to those

              22        matters, I believe them to be true. If called upon to testify thereto, I could and would competently

              23        do so under oath.

              24        2.         Defendant’s website states that Defendant was featured on CBS, the Los Angeles Times,

              25        The Huffington Post, Barron’s and Expertise.

              26        3.         Defendant threatened to sue Plaintiff for malicious prosecution in a letter to the LWDA.

              27        Attached hereto as Exhibit A is a true and correct copy of a letter Defendant wrote to the LWDA.

              28        4.         Defendant filed a motion in this Court to compel Plaintiff’s deposition one week after
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                                                                         DECLARATION OF JONATHAN J. DELSHAD