On December 20, 2017 a
Legacy Document - LEGACY DOCUMENT TYPE: Opposition
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.
Preview
v ‘ I E
nfe/‘ed IMO
1 Howard S. Fisher, Esq. (Cal. Bar No.70835) FILED
LAW OFFICES OF HOWARD S' FISHER Su erior Court of California
23 Tel: (310)553-2000
0'
MAY 09 2019
Fax: (310) 553-0012 4 _
4 E-mail: HSF@HowardSFisher.com Sherri F1 Caef. E§l|V€;01"°9T/Clerk
By Deputy
5 Attorneys for Defendant 1”" J“a'°’
Network Depositions Services, Inc.
6
7
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF LOS ANGELES - SANTA MONICA
10
ll
12 GARRETT D. LEEVERS, Case No. SC128570
13 Plaintiff,
DEFENDANT NETWORK DEPOSITION
14 v. SERVICES’ OPPOSITION TO
15 PLAINTIFF’S EX PARTE APPLICATION
NETWORK DEPOSITION SERVICES. RE FILING AMENDED COMPLAINT
16 INC., and DOES I through 20. inclusive.
17 Defendants.
Date: May 9, 2018
18 Time: 8:30 a.m.
Department: WE - K
19 Judge: Hon. Gerald Rosenberg
20
21 A. Background
22 . . . . . .
PlaintiffGarrett D. Leevers is a minority shareholder of Defendant Network Deposition Services,
23 Inc (“Network”). Network is a prominent court reporting company.
24 -
Plaintiff’ s former counsel caused to be filed the original complaint that was verified, and
25 .
subsequently a non-verified complaint was filed - even though Corporations Code § 1800 requires a
2 . . . - . .
6 veried complaint. Defendant Network has filed a motion to strike.
27
‘ Network has offered to stipulate to an amended complaint that cures the verification defect.
' 28 . .0 . . . .- .
1‘ However, Plaintiff has not responded to that offer. It all Plaintiff wants to do is cure the verification.
1
Defendant Network Opposition to P|aintiff’s Ex Parte Re Amended Complaint
Document Filed Date
May 09, 2018
Case Filing Date
December 20, 2017
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v ‘ I E nfe/‘ed IMO 1 Howard S. Fisher, Esq. (Cal. Bar No.70835) FILED LAW OFFICES OF HOWARD S' FISHER Su erior Court of California 23 Tel: (310)553-2000 0' MAY 09 2019 Fax: (310) 553-0012 4 _ 4 E-mail: HSF@HowardSFisher.com Sherri F1 Caef. E§l|V€;01"°9T/Clerk By Deputy 5 Attorneys for Defendant 1”" J“a'°’ Network Depositions Services, Inc. 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES - SANTA MONICA 10 ll 12 GARRETT D. LEEVERS, Case No. SC128570 13 Plaintiff, DEFENDANT NETWORK DEPOSITION 14 v. SERVICES’ OPPOSITION TO 15 PLAINTIFF’S EX PARTE APPLICATION NETWORK DEPOSITION SERVICES. RE FILING AMENDED COMPLAINT 16 INC., and DOES I through 20. inclusive. 17 Defendants. Date: May 9, 2018 18 Time: 8:30 a.m. Department: WE - K 19 Judge: Hon. Gerald Rosenberg 20 21 A. Background 22 . . . . . . PlaintiffGarrett D. Leevers is a minority shareholder of Defendant Network Deposition Services, 23 Inc (“Network”). Network is a prominent court reporting company. 24 - Plaintiff’ s former counsel caused to be filed the original complaint that was verified, and 25 . subsequently a non-verified complaint was filed - even though Corporations Code § 1800 requires a 2 . . . - . . 6 veried complaint. Defendant Network has filed a motion to strike. 27 ‘ Network has offered to stipulate to an amended complaint that cures the verification defect. ' 28 . .0 . . . .- . 1‘ However, Plaintiff has not responded to that offer. It all Plaintiff wants to do is cure the verification. 1 Defendant Network Opposition to P|aintiff’s Ex Parte Re Amended Complaint