Motion,Ex Parte: ARA KIUPELIAN, ET AL. VS GEORGE GEMAYEL, ET AL.

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                                MARC Y. LAZO, SBN: 215998
 1   SUSAN BALISTOCKY, SBN:
     K&L LAW GROUP, P.C.
 2
     2646 Dupont Drive, Suite 60340
 3   Irvine, California 92612
     Phone No.:      (949) 216-4000
 4   Fax No.:        (800) 596-0370
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     Attorneys for Defendants
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 7                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                         COUNTY OF LOS ANGELES
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10                                                 )
      ARA KIUPELIAN, VARDAN                        )   Case No: 19STCV21444
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      KIUPELIAN,                                   )
12                                                 )   NOTICE OF MOTION AND MOTION TO
                            Plaintiff,             )   STRIKE PORTIONS OF THE COMPLAINT;
13                                                 )   MEMORANDUM OF POINTS AND
              vs.                                  )   AUTHORITIES; DECLARATION OF SUE
14                                                     BALISTOCKY IN SUPPORT THEREOF
                                                   )
15    GEORGE GEMAYEL, GREENKRAFT,                  )
      INC., a corporation, and DOES 1              )   RESERVATION NO. 400492848402
16    through 10,                                  )
17                                                 )
                                                       Date: October 18, 2019
                            Defendants.            )   Time: 8:30 a.m.
18                                                 )   Dept: 56
                                                   )
19                                                 )   Complaint filed: June 19, 2019
                                                       Trial Date: None Set
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21          PLEASE TAKE NOTICE that on October 18, 2019, at 8:30 a.m., or as soon thereafter as the
22   matter may be heard in Department 56 of the Los Angeles Superior Court located at 111 North Hill
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     Street, Los Angeles, CA 90012, Defendants GEORGE GEMAYEL (“Gemayel”) and GREENKRAFT,
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     INC. (“Greenkraft,” and together with Gemayel, “Defendants”) will and hereby move to strike portions
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     of the complaint of ARA KIUPELIAN, VARDAN KIUPELIAN filed with the Court on June 19, 2019.
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            The Motion to Strike is made on the grounds that the allegations made against Defendants fail to
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     support the complaint's allegations that punitive damages are warranted. The motion to strike is based
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     upon this Notice of Motion, the attached Memorandum of Points and Authorities, the meet-and-confer

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                                 MOTION TO STRIKE PORTIONS OF THE COMPLAINT