Document for ARROYO WEST HOMEOWNERS VS YOUNIS, EMAD S

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 08/19/2020 12:08 AM Sherri R. Carter, Executive Officer/Clerk of Court, by G. Villarreal,Deputy Clerk



                                                                               ARROYO WEST HOA v. YOUNIS


                1      Emad Younis
                       In Pro Per
                2      24019 arroyo park drive #31
                       Valencia Ca 91355
                3      818-357-0116
                       emadyounis@gmail.com
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                6                                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                                  COUNTY OF LOS ANGELES
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                             ARROYO WEST HOMEOWNERS ASS.,                                             ) Case No.: 17K05920
                8                                                                                     )
                                        Plaintiff
                                                                                                      ) OPPOSITION TO MOTION FOR ATTORNEY
                9                                                                                     ) FEES.
                                                            vs.                                       )
              10                                                                                      ) Date: 09/08/20
                                                 EMAD YOUNIS,                                         ) Time: 10:30 am
              11                                                                                      ) Dept: 26
                                                   Defendant                                          )
              12                                                                                      )
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                                                                                       INTRODUCTION
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                       This action superficially is made to be a collection of dues brought by plaintiff Arroyo West HOA
              16       ("Association") against Defendant Younis ("Younis") resulting in defaults that were procured by fraud
                       and misrepresentations by the attorney of record. While the true nature and intention of the case is, to
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                       force and coerce Younis out of an all white community where he had lived peacefully for the past 10
              18       years. The parties never have conducted discovery and the court never has considered any of the
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                       merits or allegations of the case.

              20       Now comes counsel of Plaintiff, shamelessly asking for an award/reward for his, by own admission,
                       ZEALOUS opposition for the past two years to vacate his fraudulently obtained defaults, knowing
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                       too well, that by doing so, there would be absolutely no benefit to his client by these actions, relying
              22       solely on his misbelief, that he can charge Younis for his exaggerated hours and rate, and using those
                       costs as a scaring tactic, to discourage Younis from exposing and undoing his perjury, lies and fraud.
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              24       Younis moves to strike and/or tax Plaintiff Memorandum of Costs on Appeal in its entirety on the
                       grounds that it is improper, never served and untimely and Plaintiff therefore has waived any right to
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                       its costs on appeal. Plaintiff is simply not the "prevailing party" pursuant to statute due to the
              26       voluntary dismissal of the action and the fact that judgment was by default procured by fraud.

              27       By way of this opposition, Younis has put Plaintiff's costs into issue. As such, the burden is on the
              28       Plaintiff to establish that the claimed costs were necessary and reasonable in amount.

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                                                            OPPOSITION TO MOTION FOR ATTORNEY FEES