Motion-Secondary: MARJORIE DEHEY, ET AL. VS DEFENDANT THE POINT AT BEVERLY HILLS INC., ET AL

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/11/2019 05:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




               1      G. David Rubin (SBN181293)
                      Hayk Ghalumyan (SBN314686)
               2      LITCHFIELD CAVO LLP
                      251 South Lake Avenue, Suite 750
               3      Pasadena, CA 91101
                      Tel: (626) 683-1100
               4      Fax: (626) 683-1113
                      Email: rubin@litchfieldcavo.com
               5             ghalumyan@litchfieldcavo.com

               6      Attorneys for Defendant,
                      Quality Control Restoration, Inc.
               7

               8                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
               9                                                    FOR THE COUNTY OF LOS ANGELES
             10

             11       MARJORIE DEHEY, an individual and as                                           Case No.: 19STCV02006
                      guardian ad litem for RYKER (a minor); PAUL                                    [Assigned to SSC, Dept. 2]
             12       OVERACKER, an individual,
                                                                                                     DECLARATION OF HAYK GHALUMYAN IN
             13                                         Plaintiff,                                   SUPPORT OF DEFENDANT QUALITY
                                                                                                     CONTROL RESTORATION, INC.’S
             14                  vs.                                                                 DEMURRER TO PLAINTIFF’S FIRST
                                                                                                     AMENDED COMPLAINT AND MOTION TO
             15       THE POINT AT BEVERLY HILLS INC., a                                             STRIKE PORTIONS OF PLAINTIFF’S FIRST
                      California corporation; QUALITY CONTROL                                        AMENDED COMPLAINT
             16       RESTORATION INC., a California
                      corporation; LB PROPERTY MANAGEMENT                                            [Reservation No. 507971195339]
             17       INC., a California Corporation, Defendant
                      VICTOR MICHAEL BARBER, an individual,                                          Date:                        August 12, 2019
             18       and DOES 1 through 25, inclusive,                                              Time:                        1:30 p.m.
                                                                                                     Dept.:                       2
             19                                         Defendants.

             20                                                                                      Complaint Filed:               January 22, 2019
                                                                                                     First Amended Complaint Filed: June 11, 2019
             21                                                                                      Trial:                         July 7, 2020

             22                                                             Declaration of Hayk Ghalumyan

             23                  I, Hayk Ghalumyan, declare as follows:

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

             25       California, and am an associate of Litchfield Cavo LLP, attorneys of record for defendant Quality

             26       Control Restoration, Inc. (“Defendant”) in the above-entitled action. As an attorney who is assigned to

             27       work on this case and upon review of the records in the file, I have personal knowledge of the facts

             28       stated herein and, if called to testify, I could and would competently testify thereto. I submit this


                                                                                                     1
                                                                       DECLARATION OF HAYK GHALUMYAN