Motion-Secondary: 632 N PALM DRIVE, LLC VS ADAN PENA, ET AL.

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/16/2021 04:08 PM Sherri R. Carter, Executive Officer/Clerk of Court, by V. Yonker,Deputy Clerk




               1        Jack M. Zakariaie (Bar No. 168776)
                        Nilou Zakariaie (Bar No. 168466)
               2        ZAKARIAIE & ZAKARIAIE
                        10100 Santa Monica Blvd., Suite 300
               3        Los Angeles, CA 90067
                        Telephone: 310-552-0066
               4        Facsimile: 310-552-4585
               5        Attorneys for Plaintiff and Cross-Defendant
                        632 N Palm Drive, LLC
               6

               7

               8                                                   SUPERIOR COURT OF CALIFORNIA
               9                                                          COUNTY OF LOS ANGELES
             10
                        632 N PALM DRIVE, LLC.                                                     CASE NO.: 19SMCV00434
             11                                                                                    Assigned to the Honorable Judge Elaine W.
                                        Plaintiff,                                                 Mandel, Dept. P
             12                             v.
                                                                                                   RESPONSE TO GOLD PACIFIC’S
             13                                                                                    OBJECTION TO PLAINTIFF’S NOTICE
                        GOLD PACIFIC CONSTRUCTION,
                                                                                                   OF RULING
             14         INC., a California corporation, ADAN
                        PENA, an individual; SURETEC
                                                                                                   Date: March 9, 2021
             15         INDEMNITY COMPANY, a California
                                                                                                   Time: 8:30 am.
                        corporation, and DOES 1-20
             16                                                                                    Dept.: “P”
                                          Defendants.
             17

             18         _________________________________
                        AND ALL CROSS-RELATED ACTIONS
             19

             20      TO ALL PARTIES, and to their ATTORNEYS OF RECORD:
             21                   Plaintiff 632 N Palm Drive LLC (“Palm”) hereby responds to Gold Pacific’s Objection
             22        to Plaintiff’s Notice of Ruling dated March 11, 2021 and Declaration of Sean Reynolds in
             23        support thereof.
             24                   At the outset, it should be noted that the Objection and Declaration are replete with false
             25        statements with the intention to create a fictional and false record, as is Mr. Reynolds’ practice
             26        and custom, which has not only been chastised by the Court repeatedly, but for which Mr.
             27        Reynolds’ has been monetarily and non-monetarily sanctioned including but not limited to an
             28        order for Mr. Reynolds to attend a 4 hour ethics/civility MCLE course . In other words, Mr.
ZAKARIAIE
   &                                                                                              -1-
ZAKARIAIE
                                                    PLAINTIFF’S RESPONSE TO OBJECTIONS TO NOTICE OF RULING