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Alan A. Ahdoot, Esq. (State Bar No. 238594)
Christopher B. Adamson, Esq. (State Bar N0. 238500)
Arash Nematollahi, Esq. (State Bar No. 225306)
SUPEURIORFCOIU%T§F CDALIFOR
m
CSOAfi‘gégASRAowgors/Sm%#o
ADAMSON AHDOOT LLP
1150 s. Robertson Blvd. MAY 2 3 2022
Los Angeles, California 90035
T: (310) 888-0024/ F: (888) 895-4665 BY
E: alan(d>aa—llp.com; christopher@aa—llp.com ANTHONY Ngfi’l’mfiz. :55? n.
UT?
E: arashgibaa-llgcom
Attorneys for Plaintiffs
GARY LEE BROWN and LANDON LEVI BROWN-EARLS, a minor,
By and through his Guardian Ad Litem, CHALLACE SHANISE EARLS;
as successors in interest 0f JUSTIN LEE BROWN, deceased.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO - UNLIMITED JURISDICTION
11
12 SHERRY TYSON, and individual and as Case No.: CIVD82017344
successor in interest; [Consolidated with: CIVDS2020541]
13
Plaintiff, NOTICE OF MOTION AND MOTION
14 vs. TO COMPEL THE DEPOSITION 0F
DEFENDANTS’ EMPLOYEE SHONA
15 ONTARIO CNG STATION, INC; ONTARIO VIENTA; REQUEST FOR ORDER
CNG PROPERTY, INC, a business entity form AWARDING MONETARY
16 unknown; DIKRAN ARABIAN, and individual; SANCTIONS AGAINST DEFENDANTS
GARY LEE BROWN, an individual named as a ONTARIO CNG STATION, INC.;
17 nominal defendant; and DOES 1-100, ONTARIO CNG PROPERTY, LLC;
INCLUSIVE, DIKRAN ARABIAN AND THEIR
18 ATTORNEYS OF RECORD, BORDIN
Defendants, _
SEMMER LLP IN THE SUM 0F
19 $1,500.00; MEMORANDUM OF
POINTS AND AUTHORITIES;
20 AND RELATEDCONSOLIDATED ACTION DECLARATION 0F ARASH
NEMATOLLAHI
21
Filed concurrently with [PROPOSED]
22 ORDER
23 Date: July 12, 2022
Time: 8:30 am.
24 Dept: 828
[RESERVED]
25
Complaint Filed: December 8, 2020
26 Trial Date: November 7, 2022
27
28
NOTICE OF MOTION AND MOTION TO COMPEL THE DEPOSITION OF DEFENDANTS’ EMPLOYEE
SHONAVIENTA
1
TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on July 12, 2022, at 8:30 a.m., or as soon thereafter as
the matter may be heard in Department $28 of the above-entitled court, located at 247 West 3rd
Street, San Bernardino, CA 9241 5, Plaintiff, LANDON LEVI BROWN-EARLS, a minor, By and
through his Guardian Ad Litem, CHALLACE SHANISE EARLS; as successors in interest of
JUSTIN LEE BROWN, deceased (hereinafter referred t0 as “PLAINTIFF BROWN”) will move
the court for an order compelling Defendants ONTARIO CNG STATION, INC; ONTARIO CNG
PROPERTY, LLC; and DIKRAN ARABIAN (hereinafter referred to as “DEFENDANTS”) to
produce Defendants’ employee SHONA VIENTA (hereinafter referred to as “VIENTA”) to
10 appear and testify at her properly noticed deposition previously noticed for October 19, 202 1 April ,
11 18, 2022 and May 20, 2022.
12 NOTICE IS FURTHER GIVEN that Plaintiff will request that the Court award monetary
13 sanctions against Defendants ONTARIO CNG STATION, INC; ONTARIO CNG PROPERTY,
14 LLC; and DIKRAN ARABIAN and their attorneys of record, BORDIN SEMMER LLP, and in
15 favor of PLAINTIFFS’ attorneys of record, ADAMSON AHDOOT LLP, in the sum 0f $1,500.00
16 for DEFENDANTS’ willful misuse of the discovery process, and for necessitating this Motion.
17 This Motion will be, and is hereby, made pursuant t0 Code osz'vil Procedure § 2025.450
18 and other applicable statutes. This motion is further based upon this notice, the attached
19 Memorandum 0f Points and Authorities, the Declaration of Arash Nematollahi filed herewith;
20 upon the records and files in this action; and upon such further evidence and argument as may be
21 presented prior to or at the time of hearing on the motion.
22
Dated: May 23, 2022 Respectfillly Submitted,
23 ADAMSON AHDOOT LLP
24
25
ARASH NEMATOLLAHI
Attorneys for Plaintiffs
26 GARY BROWN et a1
27
28
NOTICE OF MOTION AND MOTION TO COMPEL THE DEPOSITION OF DEFENDANTS’ EMPLOYEE
SHONAVIENTA
2
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Alan A. Ahdoot, Esq. (State Bar No. 238594) Christopher B. Adamson, Esq. (State Bar N0. 238500) Arash Nematollahi, Esq. (State Bar No. 225306) SUPEURIORFCOIU%T§F CDALIFOR m CSOAfi‘gégASRAowgors/Sm%#o ADAMSON AHDOOT LLP 1150 s. Robertson Blvd. MAY 2 3 2022 Los Angeles, California 90035 T: (310) 888-0024/ F: (888) 895-4665 BY E: alan(d>aa—llp.com; christopher@aa—llp.com ANTHONY Ngfi’l’mfiz. :55? n. UT? E: arashgibaa-llgcom Attorneys for Plaintiffs GARY LEE BROWN and LANDON LEVI BROWN-EARLS, a minor, By and through his Guardian Ad Litem, CHALLACE SHANISE EARLS; as successors in interest 0f JUSTIN LEE BROWN, deceased. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO - UNLIMITED JURISDICTION 11 12 SHERRY TYSON, and individual and as Case No.: CIVD82017344 successor in interest; [Consolidated with: CIVDS2020541] 13 Plaintiff, NOTICE OF MOTION AND MOTION 14 vs. TO COMPEL THE DEPOSITION 0F DEFENDANTS’ EMPLOYEE SHONA 15 ONTARIO CNG STATION, INC; ONTARIO VIENTA; REQUEST FOR ORDER CNG PROPERTY, INC, a business entity form AWARDING MONETARY 16 unknown; DIKRAN ARABIAN, and individual; SANCTIONS AGAINST DEFENDANTS GARY LEE BROWN, an individual named as a ONTARIO CNG STATION, INC.; 17 nominal defendant; and DOES 1-100, ONTARIO CNG PROPERTY, LLC; INCLUSIVE, DIKRAN ARABIAN AND THEIR 18 ATTORNEYS OF RECORD, BORDIN Defendants, _ SEMMER LLP IN THE SUM 0F 19 $1,500.00; MEMORANDUM OF POINTS AND AUTHORITIES; 20 AND RELATEDCONSOLIDATED ACTION DECLARATION 0F ARASH NEMATOLLAHI 21 Filed concurrently with [PROPOSED] 22 ORDER 23 Date: July 12, 2022 Time: 8:30 am. 24 Dept: 828 [RESERVED] 25 Complaint Filed: December 8, 2020 26 Trial Date: November 7, 2022 27 28 NOTICE OF MOTION AND MOTION TO COMPEL THE DEPOSITION OF DEFENDANTS’ EMPLOYEE SHONAVIENTA 1 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on July 12, 2022, at 8:30 a.m., or as soon thereafter as the matter may be heard in Department $28 of the above-entitled court, located at 247 West 3rd Street, San Bernardino, CA 9241 5, Plaintiff, LANDON LEVI BROWN-EARLS, a minor, By and through his Guardian Ad Litem, CHALLACE SHANISE EARLS; as successors in interest of JUSTIN LEE BROWN, deceased (hereinafter referred t0 as “PLAINTIFF BROWN”) will move the court for an order compelling Defendants ONTARIO CNG STATION, INC; ONTARIO CNG PROPERTY, LLC; and DIKRAN ARABIAN (hereinafter referred to as “DEFENDANTS”) to produce Defendants’ employee SHONA VIENTA (hereinafter referred to as “VIENTA”) to 10 appear and testify at her properly noticed deposition previously noticed for October 19, 202 1 April , 11 18, 2022 and May 20, 2022. 12 NOTICE IS FURTHER GIVEN that Plaintiff will request that the Court award monetary 13 sanctions against Defendants ONTARIO CNG STATION, INC; ONTARIO CNG PROPERTY, 14 LLC; and DIKRAN ARABIAN and their attorneys of record, BORDIN SEMMER LLP, and in 15 favor of PLAINTIFFS’ attorneys of record, ADAMSON AHDOOT LLP, in the sum 0f $1,500.00 16 for DEFENDANTS’ willful misuse of the discovery process, and for necessitating this Motion. 17 This Motion will be, and is hereby, made pursuant t0 Code osz'vil Procedure § 2025.450 18 and other applicable statutes. This motion is further based upon this notice, the attached 19 Memorandum 0f Points and Authorities, the Declaration of Arash Nematollahi filed herewith; 20 upon the records and files in this action; and upon such further evidence and argument as may be 21 presented prior to or at the time of hearing on the motion. 22 Dated: May 23, 2022 Respectfillly Submitted, 23 ADAMSON AHDOOT LLP 24 25 ARASH NEMATOLLAHI Attorneys for Plaintiffs 26 GARY BROWN et a1 27 28 NOTICE OF MOTION AND MOTION TO COMPEL THE DEPOSITION OF DEFENDANTS’ EMPLOYEE SHONAVIENTA 2