On December 20, 2017 a
Reply - Reply to opposition to motion for protective order for the deposition subpoena of third parties; the Law Office of Jacob Emrani; the Homampour Law Firm; Daniels, Fine Israel Schonbuch & Lebovi
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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1 Howard S. Fisher, Esq. (Cal. Bar No.70835)
LAW OFFICES OF HOWARD s. FISHER S“ em FC|LnEf|% H _
2 9401 Wilshire Boulevard, Suite 1250 ' °” 9 3 ' °""a
Beverly Hills, California 90212 goumy of L05 Angekes
3 Tel: (310) 553-2000 27
Fax: (310) 553-0012
4 E-mail: HSF@HowardSFisher.com Sherri R. Caner, E tlve ticer/Clerk
Bv Deputy
5 Attorneys for Defendant be” J“"="°2
Network Depositions Services, Inc.
6
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
FOR THE COUNTY OF LOS ANGELES - SANTA MONICA
9
10
1‘ GARRETT D. LEEVERS, Case NO. SC12857O
12 Plaintiff, REPLY TO OPPOSITION TO MOTION
13 FOR PROTECTIVE ORDER FOR THE
v. DEPOSITION SUBPOENAS OF THIRD
14 PARTIES: (1.) THE LAW OFFICE OF
NETWORK DEPOSITION SERVICES, JACOB EMRANI; (2.) THE HOMAMPOUR
15 INC., and DOES 1 through 20, inclusive, LAW FIRM; and (3.) DANIELS, FINE,
ISRAEL, SCHONBUCH & LEBOVITS, LLP
16 Defendants.
17 Date: December 4, 2018
Time: 8:30 a.1n.
18 Dept: K
Judge: Hon. Gerald Rosenberg
19 RES 11): 180504311682
20
21 TO ALL PARTIES OF RECORD AND THE COURT:
22 Network Deposition Services Inc., hereby submits its Reply to Garrett Levers’ Opposition to
23 the pending Motion for Protective Order:
24 Unfortunately as this Court recently witnessed in previous motion practice with counsel for
25 Plaintiff, and continues throughout the Opposition, counsel for Plaintiff appears to have a strained
26 relationship with truth.
27 1. As of November 21, 2018, no Third Amended Complaint has been received, and
‘V 28 there is no record of it being led with the Court
1
Reply - Protective Order
Document Filed Date
November 27, 2018
Case Filing Date
December 20, 2017
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1 Howard S. Fisher, Esq. (Cal. Bar No.70835) LAW OFFICES OF HOWARD s. FISHER S“ em FC|LnEf|% H _ 2 9401 Wilshire Boulevard, Suite 1250 ' °” 9 3 ' °""a Beverly Hills, California 90212 goumy of L05 Angekes 3 Tel: (310) 553-2000 27 Fax: (310) 553-0012 4 E-mail: HSF@HowardSFisher.com Sherri R. Caner, E tlve ticer/Clerk Bv Deputy 5 Attorneys for Defendant be” J“"="°2 Network Depositions Services, Inc. 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF LOS ANGELES - SANTA MONICA 9 10 1‘ GARRETT D. LEEVERS, Case NO. SC12857O 12 Plaintiff, REPLY TO OPPOSITION TO MOTION 13 FOR PROTECTIVE ORDER FOR THE v. DEPOSITION SUBPOENAS OF THIRD 14 PARTIES: (1.) THE LAW OFFICE OF NETWORK DEPOSITION SERVICES, JACOB EMRANI; (2.) THE HOMAMPOUR 15 INC., and DOES 1 through 20, inclusive, LAW FIRM; and (3.) DANIELS, FINE, ISRAEL, SCHONBUCH & LEBOVITS, LLP 16 Defendants. 17 Date: December 4, 2018 Time: 8:30 a.1n. 18 Dept: K Judge: Hon. Gerald Rosenberg 19 RES 11): 180504311682 20 21 TO ALL PARTIES OF RECORD AND THE COURT: 22 Network Deposition Services Inc., hereby submits its Reply to Garrett Levers’ Opposition to 23 the pending Motion for Protective Order: 24 Unfortunately as this Court recently witnessed in previous motion practice with counsel for 25 Plaintiff, and continues throughout the Opposition, counsel for Plaintiff appears to have a strained 26 relationship with truth. 27 1. As of November 21, 2018, no Third Amended Complaint has been received, and ‘V 28 there is no record of it being led with the Court 1 Reply - Protective Order