On December 20, 2017 a
Declaration - Declaration Declaration of Demurring or Moving Party in Support of Automatic Extension
was filed
involving a dispute between
Leevers Garrett D.,
Network Deposition Services Inc.,
Yossefi Nuriel,
Yossefi Uriel,
and
Network Deposition Services Inc.,
Yossefi Nuriel,
Yossefi Uriel,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/24/2019 10:34 AM Sherri R. Carter, Executive Officer/Clerk of Court, by T. Holmes,Deputy Clerk
CIV-141
Alto N N NY ON Ni-. N i1-t coj I 111000Ev S TATE 11000. 1 00748 000 00001 USE ONLY
savo Michael E. Friedman, Esq.
Ne-o Law Office of Steven R. Friedman
SIzEtAONO0. 1880 Century Park East, Suite 1411
100* Los Angeles CA 0 0:1 90067
(310) 273-2505
Garrett 0. Leevers
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
1725 Main Street
1725 Main Street
Monica, CA 90401
Central District
QOER GarretiD. Leevers
0EEENDAr4 i1osPryjoE;ir Netvark Depcsttion Services. Inc
DECLARATION OF DEMURRING OR MOVING PARTY
IN SUPPORT OF AUTOMATIC EXTENSION
0’ ‘:
Garrett 0. Leevers. LitiCourt Corporation
(specify):
a the oh :j tIed a Pan.
2. flora demurrer or rn.ohon to strike, a responsive pleadine is due or. (haley) January 25, 2019
DECLARATION
intend to Pie demurrer, motion to strike, or motion for judoment on the pleadings in this action. Before icon do so, t am required to
meet and confer with the party who filed the pieading that t am responding to et least five days before the date when the responsive
pleading is due (if am fifng a demurrer or motion to strike) and at ieast five days before the last day a motion for judgment on the
pleadings may be Pled (if t am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not
previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements
of Code of C’ivl Procedure sections 430.41, 435.5. or 439, [. am entitied to an automatic 30-day extension of time within which to file a
responsive pleading or motion for judgment on the pleadinos.
I made a good faith attempt to meet and confer with the part’ vhu filed the pleading at least five days before the ate the responsive
pieadirtu was due (if I am tiling a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadings may be filed (if I am filing a motion for judgment on the pleadings). l was unable to meet with that party because
tIPs- reas-ons why the parties could not meet and confer are s¼ieo)
elcw ri.
on form MC-031, Attached Declaration
Opposing counsel is on vacation, and is out of town for the second lime this month.
declare under oerraitv of aeraro 000cr the. a.,vs c-f thr-: Stoc of California ttra-t the inibrmatiori above is true end correct.
Datc’: January 24, 2019
Michael E. Friedman
- A0’ ON ATT.NiEY
.0 Li H 0-N
T I :0 1i,i V 15 ON Ao or.: NA N 1 0.1.: T0 (0101
A 1
ccerzfeo:Prcoro-rr
DECLARATION OF DEMURRING OR MOVING PARTY
IN SUPPORT OF AUTOMATIC EXTENSION
Document Filed Date
January 24, 2019
Case Filing Date
December 20, 2017
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/24/2019 10:34 AM Sherri R. Carter, Executive Officer/Clerk of Court, by T. Holmes,Deputy Clerk CIV-141 Alto N N NY ON Ni-. N i1-t coj I 111000Ev S TATE 11000. 1 00748 000 00001 USE ONLY savo Michael E. Friedman, Esq. Ne-o Law Office of Steven R. Friedman SIzEtAONO0. 1880 Century Park East, Suite 1411 100* Los Angeles CA 0 0:1 90067 (310) 273-2505 Garrett 0. Leevers SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles 1725 Main Street 1725 Main Street Monica, CA 90401 Central District QOER GarretiD. Leevers 0EEENDAr4 i1osPryjoE;ir Netvark Depcsttion Services. Inc DECLARATION OF DEMURRING OR MOVING PARTY IN SUPPORT OF AUTOMATIC EXTENSION 0’ ‘: Garrett 0. Leevers. LitiCourt Corporation (specify): a the oh :j tIed a Pan. 2. flora demurrer or rn.ohon to strike, a responsive pleadine is due or. (haley) January 25, 2019 DECLARATION intend to Pie demurrer, motion to strike, or motion for judoment on the pleadings in this action. Before icon do so, t am required to meet and confer with the party who filed the pieading that t am responding to et least five days before the date when the responsive pleading is due (if am fifng a demurrer or motion to strike) and at ieast five days before the last day a motion for judgment on the pleadings may be Pled (if t am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements of Code of C’ivl Procedure sections 430.41, 435.5. or 439, [. am entitied to an automatic 30-day extension of time within which to file a responsive pleading or motion for judgment on the pleadinos. I made a good faith attempt to meet and confer with the part’ vhu filed the pleading at least five days before the ate the responsive pieadirtu was due (if I am tiling a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (if I am filing a motion for judgment on the pleadings). l was unable to meet with that party because tIPs- reas-ons why the parties could not meet and confer are s¼ieo) elcw ri. on form MC-031, Attached Declaration Opposing counsel is on vacation, and is out of town for the second lime this month. declare under oerraitv of aeraro 000cr the. a.,vs c-f thr-: Stoc of California ttra-t the inibrmatiori above is true end correct. Datc’: January 24, 2019 Michael E. Friedman - A0’ ON ATT.NiEY .0 Li H 0-N T I :0 1i,i V 15 ON Ao or.: NA N 1 0.1.: T0 (0101 A 1 ccerzfeo:Prcoro-rr DECLARATION OF DEMURRING OR MOVING PARTY IN SUPPORT OF AUTOMATIC EXTENSION