On July 26, 2008 a
Motion to Disqualify Counsel
was filed
involving a dispute between
Ai Zishen,
Tang Baohong,
Universal Plastics Recycling Inc,
and
Tang Baohong,
Universal Plastics Recycling Inc,
Universal Plastics Recycling Inc. An Active California Corporation,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/12/2020 02:21 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Gonzalez,Deputy Clerk
1 Barry A. Bradley, Esq., State Bar No. 125353
bbradley@bglawyers.com
2 Lily Nhan, Esq., State Bar No. 289443
lnhan@bglawyers.com
3 Darren P. Salute, Esq., State Bar No. 175285
dsalute@bglawyers.com
4 BRADLEY & GMELICH LLP
700 North Brand Boulevard, 10th Floor
5 Glendale, California 91203-1202
Telephone: (818) 243-5200
6 Facsimile: (818) 243-5266
7 Attorneys for Defendants and Cross-
Complainants, BAOHONG TANG and
8 UNIVERSAL PLASTICS RECYCLING, INC.
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF LOS ANGELES, CENTRAL DISTRICT
11
12 ZISHEN AI, an individual, Case No. KC070432
(Assigned to the Hon. Peter A. Hernandez)
13 Plaintiff,
NOTICE OF MOTION AND MOTION OF
14 vs. DEFENDANTS/CROSS-COMPLAINANTS,
BAOHONG TANG AND UNIVERSAL
15 BAOHONG TANG, an individual; PLASTICS RECYCLING, INC. TO
UNIVERSAL PLASTICS RECYCLING DISQUALIFY PLAINTIFFS’ COUNSEL
16 INC., an active California corporation; and AARON MCKOWN AND HIS LAW FIRM
DOES 1 through 20, inclusive, NAVARRO & MCKOWN;
17 MEMORANDUM OF POINTS AND
Defendant. AUTHORITIES; DECLARATIONS OF
18 LILY NHAN, ESQ. AND BAOHONG
TANG
19 BAOHONG TANG and UNIVERSAL
PLASTICS RECYCLING INC., [Rules Prof. Conduct, Rules 1.9, 1.10]
20
Cross-Complainants, Date: December 8, 2020
21 Time: 9:30 a.m.
vs. Dept.: O
22
ROES 1-100, Reservation No.: 683440273652
23
Cross-Defendant. Complaint Filed: 07/05/2018
24 Trial Date: None Set
25
26 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD:
27 PLEASE TAKE NOTICE THAT on December 8, 2020, at 9:30 a.m., or as soon
28 thereafter as counsel may be heard, in Department O of the above-captioned court, located at 400
BAOHONG TANG AND UNIVERSAL PLASTICS RECYCLING, INC.’S MOTION TO DISQUALIFY
PLAINTIFFS’ COUNSEL AARON MCKOWN AND HIS LAW FIRM NAVARRO & MCKOWN
Document Filed Date
November 12, 2020
Case Filing Date
July 26, 2008
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 11/12/2020 02:21 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Gonzalez,Deputy Clerk 1 Barry A. Bradley, Esq., State Bar No. 125353 bbradley@bglawyers.com 2 Lily Nhan, Esq., State Bar No. 289443 lnhan@bglawyers.com 3 Darren P. Salute, Esq., State Bar No. 175285 dsalute@bglawyers.com 4 BRADLEY & GMELICH LLP 700 North Brand Boulevard, 10th Floor 5 Glendale, California 91203-1202 Telephone: (818) 243-5200 6 Facsimile: (818) 243-5266 7 Attorneys for Defendants and Cross- Complainants, BAOHONG TANG and 8 UNIVERSAL PLASTICS RECYCLING, INC. 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 11 12 ZISHEN AI, an individual, Case No. KC070432 (Assigned to the Hon. Peter A. Hernandez) 13 Plaintiff, NOTICE OF MOTION AND MOTION OF 14 vs. DEFENDANTS/CROSS-COMPLAINANTS, BAOHONG TANG AND UNIVERSAL 15 BAOHONG TANG, an individual; PLASTICS RECYCLING, INC. TO UNIVERSAL PLASTICS RECYCLING DISQUALIFY PLAINTIFFS’ COUNSEL 16 INC., an active California corporation; and AARON MCKOWN AND HIS LAW FIRM DOES 1 through 20, inclusive, NAVARRO & MCKOWN; 17 MEMORANDUM OF POINTS AND Defendant. AUTHORITIES; DECLARATIONS OF 18 LILY NHAN, ESQ. AND BAOHONG TANG 19 BAOHONG TANG and UNIVERSAL PLASTICS RECYCLING INC., [Rules Prof. Conduct, Rules 1.9, 1.10] 20 Cross-Complainants, Date: December 8, 2020 21 Time: 9:30 a.m. vs. Dept.: O 22 ROES 1-100, Reservation No.: 683440273652 23 Cross-Defendant. Complaint Filed: 07/05/2018 24 Trial Date: None Set 25 26 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD: 27 PLEASE TAKE NOTICE THAT on December 8, 2020, at 9:30 a.m., or as soon 28 thereafter as counsel may be heard, in Department O of the above-captioned court, located at 400 BAOHONG TANG AND UNIVERSAL PLASTICS RECYCLING, INC.’S MOTION TO DISQUALIFY PLAINTIFFS’ COUNSEL AARON MCKOWN AND HIS LAW FIRM NAVARRO & MCKOWN