Document for EDGAR GODINEZ VS SMC APPAREL INC

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                                E lectronically FILE D by Superior Court of California, County of Los Angeles on 01/24/2019 06:43 PM Sherri R. Carter, Executive Officer/Clerk of Cour, by A. Pergler,Deputy Clerk




                                Kevin A. Lipeles (Bar No. 244275)
                                    kevin@kallaw.com
                                 Thomas H. Schelly (Bar No. 217285)
                                    thomas@kallaw.com
                                 LIPELES LAW GROUP, APC
                                 880 Apollo Street, Suite 336
                                 El Segundo, California 90245
                                 Telephone: (310) 322-2211
                                 Fax: (310) 322-2252

                                 Attorneys for Plaintiff,
                                 EDGAR GODINEZ


                                                                           SUPERIOR COURT OF CALIFORNIA

                                                               COUNTY OF LOS ANGELES, CENTRAL DISTRICT
                          10

                          11     EDGAR            GODINEZ, an individual,                                 Case No. BC683757

                          12                            Plaintiff,                                        DECLARATION OF TODD VOLLUCCI
                                                                                                          RE CALCULATION OF SPECIAL
                          13                Vv                                                            DAMAGES AND INTERST FOR COURT
                                                                                                          JUDGMENT AFTER DEFAULT
                          14     SMC APPAREL, INC., a California
                                 corporation; and DOES 1 through 100,
                          15     inclusive,

                          16                                                    Defendants.

                          17

                          18     I, Todd Vollucci, declare:

                          19                 1          I have personal knowledge of the matters stated herein. If called as a witness, I
                          20     could and would testify truthfully and competently thereto under oath.

                          21                 2.         I am an attorney at law, duly licensed to practice before all courts in the State of

                          22     California, and I am duly admitted to practice in the United States District Court, Central District

                          23     of California. I am of counsel to the firm Lipeles Law Group APC ("LLG"). | am personally

                          24     familiar with the matters stated herein, and if called upon to testify, I could and would testify

                          25     accordingly.

                          26                 3           My practice includes representing businesses and individuals with federal and state

                          27     tax issues involving the Internal Revenue Service, Franchise Tax Board and the Board of

                          28     Equalization as well as business entity structuring and compliance. In addition to my tax work I



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                                    DECLARATION OF TODD VOLLUCCI RE CALCULATION OF SPECIAL DAMAGES AND INTERST