On January 25, 2019 a
Party Discovery
was filed
involving a dispute between
California Fire Protection Coalition,
Del Toro Trejo, Juan Carlos,
Filed By: Fire Guard Corporation,
Fire Guard Corporation,
Shahangian, Bahman Brian,
and
California Department Of Forestry And Fire Protection,
California Office Of The State Fire Marshal,
Dennis Mathisen In His Official Capacity As State Fire Marshal,
Does 1-10,
Jeffery Schwartz In His Official Capacity As Deputy State Fire Marshall,
Mike Richwine In His Official Capacity As State Fire Marshal,
for (Civil Rights/Discrimination)
in the District Court of Sacramento County.
Preview
I'l LED
1 TIMOTHY V. KASSOUNI, SBN 142907
KASSOUNI LAW 2013.JAN 3 ! PH 3=01
2 621 Capitol Mall, Suite 2025
Sacramento, CA 95814 jPERlOR COURT OF CALIFORHiA
3 COUSTY OF SACRAMEHFO '
Telephone: (916) 930-0030
4 Facsimile: (916)930-0033
E-Mail: Timothy@Kassounilaw.com
5
Attomeys for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Califomia Fire
6 Protection Coalition
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 CITY AND COUNTY OF SACRAMENTO
O
10
9 FIRE GUARD CORPORATION; Case No: 34-2019-00249221 -CU-CR-GDS
3 oa ~
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12
J CO o\ ^ 527 and Califomia Rules of Court, Rules 3.1150 and 3.1200, et seq. It is made on the grounds
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27.
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ProofOfService
1 TIMOTHY V. KASSOUNI, SBN 142907
KASSOUNI LAW
2 621 Capitol Mall, Suite 2025
Sacramento, CA 95814
3
Telephone: (916) 930-0030
4 Facsimile: (916) 930-0033
E-Mail: Timothy@KassoxmiIaw.com
5
Attomeys for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Califomia Fire
6 Protection Coalition
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNL\
9 CITY AND COUNTY OF SACRAMENTO
m
cn 10
o FIRE GUARD CORPORATION; Case No: 34-2019-00249221-CU-CR-GDS
cn 11
CN Ov BAHMAN BRL\N SHAHANGIAN, an
12 individual; and CALIFORNL\ FIRE
VO PROTECTION COALmON, a Califomia [PROPOSED] TEMPORARY
^^.< Corporation, RESTRAINING ORDER AND ORDER
13
I
o
cn
14 Plaintiffs,
TO SHOW CAUSE RE PRELIMINARY
INJUNCTION
— to 15 V. Date: February 1,2019
cs
>o
16 Time: 9:00 A.M.
CALIFORNL\ DEPARTMENT OF Dept.: 53
E2 Judge: Hon. David I. Brown
17 FORESTRY AND FIRE PROTECTION;
CALIFOR>nA OFFICE OF THE STATE
18 FIRE MARSHAL; DENNIS MATHISEN, in
19 his official edacity as State Fire Marshal;
JEFFERY SCHWARTZ, in his official
20 capacity as Deputy State Fire Marshall; and
DOES 1-10, inclusive.
21
Defendants.
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23
24
25
26
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28
i Jilll31M_J
-1-
PROPOSED ORDER
1 ORDER TO SHOW CAUSE
2 To Defendants Califomia Department of Forestry and Fire Protection; Califomia Office of
3 the State Fire Marshal; Dennis Mathisen; and Jeffery Schwartz;
4 Based upon the Complaint for Declaratory and Injunctive Relieffiledin this action, and
5 the supporting declarations and memorandum of points and authorities, you are ordered to appear
6 on at 2:00 P.M. in Department 53 oftiiisCourt, located at 813 6* Street, Sacramento,
7 CA, to show cause why a preliminary injunction should not be ordered staying the operation and
8 enforcement of the regulations contained within Title 19, Division 1, Chapter 5.5 of the
9 Califomia Code of Regulations (19 C C R . section 920 et. seq.), pending trial in this action.
cn
cn 10
9
o
cn
Ov 11 TEMPORARY RESTRAINING ORDER
12 Pending hearing on the Order to Show Cause, the operation and enforcement of the
U CO
13
•
*
regulations contained within Titie 19, Division 1, Chapter 5.5 of the Califomia Code of
Q- 14 Regulations (19 C C R . section 920 et. seq.), is hereby stayed.
6
cn 15
CN
VO Ov
vo 16 IT IS FURTHER ORDERED THAT:
Ov
f2 17 This Order to Show Cause and Temporary Restraining Order and supporting papers shall
18 be served on defendant no later than by ovemight mail and electroiuc mail. Proof of such
19 service shall befiledat least three court days prior to the hearing.
»0 ON
OS ^—' 20 Any opposition papers to the Order to Show Cause shall befiledand served on Plaintiffs
o* •
21 by ovemight mail and electronic mail no later than . Any reply papers to the opposition
22 shall be filed and served on Defendants by ovemight mail and electronic mail no later than .
23 The restraining order granted herein shall expire on .
24
25 Date:
26
27 Judge of the Superior Court
28
-2-
PROPOSED ORDER
Document Filed Date
January 31, 2019
Case Filing Date
January 25, 2019
Category
(Civil Rights/Discrimination)
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Preview
I'l LED 1 TIMOTHY V. KASSOUNI, SBN 142907 KASSOUNI LAW 2013.JAN 3 ! PH 3=01 2 621 Capitol Mall, Suite 2025 Sacramento, CA 95814 jPERlOR COURT OF CALIFORHiA 3 COUSTY OF SACRAMEHFO ' Telephone: (916) 930-0030 4 Facsimile: (916)930-0033 E-Mail: Timothy@Kassounilaw.com 5 Attomeys for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Califomia Fire 6 Protection Coalition 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 CITY AND COUNTY OF SACRAMENTO O 10 9 FIRE GUARD CORPORATION; Case No: 34-2019-00249221 -CU-CR-GDS 3 oa ~ < ' a m Ov 12 J CO o\ ^ 527 and Califomia Rules of Court, Rules 3.1150 and 3.1200, et seq. It is made on the grounds M 00 12 < « <^ d == < 13 S:S o- CO 2 u 14 <¥1 •—4 CM W A 15 VO 16 E2J 17 18 19 20 21 22 23 24 25 26 27. 28 ProofOfService 1 TIMOTHY V. KASSOUNI, SBN 142907 KASSOUNI LAW 2 621 Capitol Mall, Suite 2025 Sacramento, CA 95814 3 Telephone: (916) 930-0030 4 Facsimile: (916) 930-0033 E-Mail: Timothy@KassoxmiIaw.com 5 Attomeys for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Califomia Fire 6 Protection Coalition 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNL\ 9 CITY AND COUNTY OF SACRAMENTO m cn 10 o FIRE GUARD CORPORATION; Case No: 34-2019-00249221-CU-CR-GDS cn 11 CN Ov BAHMAN BRL\N SHAHANGIAN, an 12 individual; and CALIFORNL\ FIRE VO PROTECTION COALmON, a Califomia [PROPOSED] TEMPORARY ^^.< Corporation, RESTRAINING ORDER AND ORDER 13 I o cn 14 Plaintiffs, TO SHOW CAUSE RE PRELIMINARY INJUNCTION — to 15 V. Date: February 1,2019 cs >o 16 Time: 9:00 A.M. CALIFORNL\ DEPARTMENT OF Dept.: 53 E2 Judge: Hon. David I. Brown 17 FORESTRY AND FIRE PROTECTION; CALIFOR>nA OFFICE OF THE STATE 18 FIRE MARSHAL; DENNIS MATHISEN, in 19 his official edacity as State Fire Marshal; JEFFERY SCHWARTZ, in his official 20 capacity as Deputy State Fire Marshall; and DOES 1-10, inclusive. 21 Defendants. 22 23 24 25 26 27 28 i Jilll31M_J -1- PROPOSED ORDER 1 ORDER TO SHOW CAUSE 2 To Defendants Califomia Department of Forestry and Fire Protection; Califomia Office of 3 the State Fire Marshal; Dennis Mathisen; and Jeffery Schwartz; 4 Based upon the Complaint for Declaratory and Injunctive Relieffiledin this action, and 5 the supporting declarations and memorandum of points and authorities, you are ordered to appear 6 on at 2:00 P.M. in Department 53 oftiiisCourt, located at 813 6* Street, Sacramento, 7 CA, to show cause why a preliminary injunction should not be ordered staying the operation and 8 enforcement of the regulations contained within Title 19, Division 1, Chapter 5.5 of the 9 Califomia Code of Regulations (19 C C R . section 920 et. seq.), pending trial in this action. cn cn 10 9 o cn Ov 11 TEMPORARY RESTRAINING ORDER 12 Pending hearing on the Order to Show Cause, the operation and enforcement of the U CO 13 • * regulations contained within Titie 19, Division 1, Chapter 5.5 of the Califomia Code of Q- 14 Regulations (19 C C R . section 920 et. seq.), is hereby stayed. 6 cn 15 CN VO Ov vo 16 IT IS FURTHER ORDERED THAT: Ov f2 17 This Order to Show Cause and Temporary Restraining Order and supporting papers shall 18 be served on defendant no later than by ovemight mail and electroiuc mail. Proof of such 19 service shall befiledat least three court days prior to the hearing. »0 ON OS ^—' 20 Any opposition papers to the Order to Show Cause shall befiledand served on Plaintiffs o* • 21 by ovemight mail and electronic mail no later than . Any reply papers to the opposition 22 shall be filed and served on Defendants by ovemight mail and electronic mail no later than . 23 The restraining order granted herein shall expire on . 24 25 Date: 26 27 Judge of the Superior Court 28 -2- PROPOSED ORDER