On June 22, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Hector, Elizabeth,
and
25847 E 9Th Street, Llc,
Anza Management Company, A Corporation,
Carmona, Schochill C,
Chavez, Schochill C,
Does 2 Through 50,
J.K. Residential Services, Inc.,
Sterling Estates, A Business Entity Form Unknown,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
MARTINIAN &ASSOCIATES SUP;
.3? 9 L 5.7:".
D
Kaveh Keshmiri, Esq. (285348) cg; kIéBDISSIA
2801 Cahuenga Blvd W 82:: {,Tz’m‘T
Los An eles, CA 90068 U.
A
T
(
fl
v
022
Tel. 32§. 350-1900
Fax: 323-850-1934
Kaveh.keshmiri@martinianlaw.com
Attorneys for Plaintiff,
©00\IO\MAWN~
ELIZABETH HECTOR
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO — CENTRAL
ELIZABETH HECTOR, an individual; Case N0; CIVD82012799
Plaintiff, PLAINTIFF’S Ex PARTE APPLICATION
VS.
FOR AN ORDER T0 REOPEN DISCOVERY
FOR LIMITED PURPOSE; MEMORANDUM
STERLING ESTATES ct aL; and DOES 1 to 0F POINTS AND AUTHORITIES;
50, Inclusive. DECLARATION 0F KAVEH KESHMIRI,
ESQ; AND [PROPOSED] ORDER
D efendants.
Ex Parte Date: October l0, 2022
Ex Parte Time: 8:30 a.m.
Ex Parte Location: Dept S33
Current Trial Date : March 23, 2023
NNNNNNNNu—ud—ah—t—a—n_udu——~
qmmg‘IJN—CQWQQU‘AWNF‘O
TO THE COURT AND TO ALL ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on October 10, 2022, at 8:30 a.m., in Department
S33 of the above-entitled court, located at 247 W 3rd Street San Bemardino, CA 92405,
or as soon thereafter as it may be heard by the court, Plaintiff will apply ex parte for
an order to reopen discovery for limited purpose of taking defendant’s deposition.
The trial is currently set for March 23, 2023.
This exparte application is made based on the grounds that Plaintiff s firm made
Fax a mistake that is excusable pursuant to CCP 473(b). Namely, Plaintiff ELIZABETH
HECTOR’s former handling attorney, Kiara Mbasa, and David Vartanian left the
firm and current counsel, Kaveh Keshmiri took over the files
3y plaintiff’s in 2022, in
1
PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER TO REOPEN DISCOVERY; MEMORANDUM
OF POINTS AND AUTHORITIES; DECLARATION OF KAVEH KESHMIRI. ESQ; AND [PROPOSED]
ORDER
summer 2022. Current counsel needs additional time to take the deposition of
defendant. Defendant suffers no prejudice by the reopening of discovery for that
purpose.
This application is being brought pursuant to California Rules of Court, Rules
3.1200, 3.1202, 3.1204, and 3.1332, the Memorandum of Points and Authorities
\DOOQO‘Ul#U-JN—
attached hereto, the Declaration of Kaveh Keshmiri, Esq., the exhibits, pleadings, and
other documents on file herein, and any oral arguments made at the time ofthe hearing.
DATED: 10/5/22 MARTINIAN & ASSOCIATES
By: ‘5‘
g i
Kaveh Keshmiri ESQ.
Attorneys for Plaintiff, Elizabeth Hector
NNNNNNNNNH—u—r—u—ut—dH-fip—I—4
mqomAU’N—‘oomfloka’JNF—‘o
2
ORDER TO REOPEN DISCOVERY; MEMORANDUM
PLAINTIFF’S EX PARTE APPLICATION FOR AN
OF POINTS AND AUTHORITIES; DECLARATION OF KAVEH KESHMIRI, ESQ; AND [PROPOSED]
ORDER
Document Filed Date
October 07, 2022
Case Filing Date
June 22, 2020
Category
Personal Injury Non-Motor Vehicle Unlimited
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Preview
MARTINIAN &ASSOCIATES SUP; .3? 9 L 5.7:". D Kaveh Keshmiri, Esq. (285348) cg; kIéBDISSIA 2801 Cahuenga Blvd W 82:: {,Tz’m‘T Los An eles, CA 90068 U. A T ( fl v 022 Tel. 32§. 350-1900 Fax: 323-850-1934 Kaveh.keshmiri@martinianlaw.com Attorneys for Plaintiff, ©00\IO\MAWN~ ELIZABETH HECTOR SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO — CENTRAL ELIZABETH HECTOR, an individual; Case N0; CIVD82012799 Plaintiff, PLAINTIFF’S Ex PARTE APPLICATION VS. FOR AN ORDER T0 REOPEN DISCOVERY FOR LIMITED PURPOSE; MEMORANDUM STERLING ESTATES ct aL; and DOES 1 to 0F POINTS AND AUTHORITIES; 50, Inclusive. DECLARATION 0F KAVEH KESHMIRI, ESQ; AND [PROPOSED] ORDER D efendants. Ex Parte Date: October l0, 2022 Ex Parte Time: 8:30 a.m. Ex Parte Location: Dept S33 Current Trial Date : March 23, 2023 NNNNNNNNu—ud—ah—t—a—n_udu——~ qmmg‘IJN—CQWQQU‘AWNF‘O TO THE COURT AND TO ALL ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on October 10, 2022, at 8:30 a.m., in Department S33 of the above-entitled court, located at 247 W 3rd Street San Bemardino, CA 92405, or as soon thereafter as it may be heard by the court, Plaintiff will apply ex parte for an order to reopen discovery for limited purpose of taking defendant’s deposition. The trial is currently set for March 23, 2023. This exparte application is made based on the grounds that Plaintiff s firm made Fax a mistake that is excusable pursuant to CCP 473(b). Namely, Plaintiff ELIZABETH HECTOR’s former handling attorney, Kiara Mbasa, and David Vartanian left the firm and current counsel, Kaveh Keshmiri took over the files 3y plaintiff’s in 2022, in 1 PLAINTIFF’S EX PARTE APPLICATION FOR AN ORDER TO REOPEN DISCOVERY; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KAVEH KESHMIRI. ESQ; AND [PROPOSED] ORDER summer 2022. Current counsel needs additional time to take the deposition of defendant. Defendant suffers no prejudice by the reopening of discovery for that purpose. This application is being brought pursuant to California Rules of Court, Rules 3.1200, 3.1202, 3.1204, and 3.1332, the Memorandum of Points and Authorities \DOOQO‘Ul#U-JN— attached hereto, the Declaration of Kaveh Keshmiri, Esq., the exhibits, pleadings, and other documents on file herein, and any oral arguments made at the time ofthe hearing. DATED: 10/5/22 MARTINIAN & ASSOCIATES By: ‘5‘ g i Kaveh Keshmiri ESQ. Attorneys for Plaintiff, Elizabeth Hector NNNNNNNNNH—u—r—u—ut—dH-fip—I—4 mqomAU’N—‘oomfloka’JNF—‘o 2 ORDER TO REOPEN DISCOVERY; MEMORANDUM PLAINTIFF’S EX PARTE APPLICATION FOR AN OF POINTS AND AUTHORITIES; DECLARATION OF KAVEH KESHMIRI, ESQ; AND [PROPOSED] ORDER