On January 26, 2016 a
Party Discovery
was filed
involving a dispute between
Moda Kevin,
and
Brivanlou Pacoima Llc,
Hakak Mahin,
Harold Igdaloff Trustee Of The Igdaloff,
for Other Real Property (not eminent domain, landlord/tenant, foreclosure) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
@ FILED
Sup erior Court of California
ountv of Los Anceles
Shari Rosenthal, Esq. (State Bar No. 123083)
Sharon S. Jeffrey, Esq. (State Bar No. 228149)
JUN 28 2017
ia —
Manning & Kass, Ellrod, Ramirez, Trester LLP Sherri R. v, ty tBAeCutive Officer/Clark
801 South Figueroa Street, 15" Floor By, Deputy
Los Angeles, CA 90017
Tel: (213) 624-6900
Fax: (213) 624-6999
Attorneys for Defendants BRIVANLOU PACOIMA, LC, MAHIN HAKAK
at
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10 /
11
12
KEVIN MODA,
Plaintiff,
Case No. BC608383
(Hon. Maureen Duffy Lewis, Dept. 38] s
NOTICE OF MOTION AND MOTION TO
‘
Vv. DEEM REQUEST FOR ADMISSIONS
13
ADMITTED; REQUEST FOR
Bs BRIVANLOU PACOIMA, LC, MAHIN SANCTIONS; MEMORANDUM OF
Qa 14
HAKAK, and DOES 1 -10, Inclusive, POINTS AND AUTHORITIES;
5s DECLARATION OF ROBERT P. WARGO
15
Defendants
Date: August 14, 2017
16
Time: 9:30 AM
17 Dept: 38
Res No. 170627230419
18
Trial: 9/11/2017
19
20 TO PLAINTIFF AND HIS COUNSEL OF RECORD:
21 PLEASE TAKE NOTICE that on August 14, 2017, at 9:30 AM, or as soon thereafter as
22 the matter may be heard Department 38 of the.abpve-entitled Court, located at 111 North Hill
23 Street, Los Angeles, CA, 90012, Defendant Brivanlou Pacoima, LC, will, and hereby does, move
24 this Court for an order deeming admitted those matters set forth in Request for Admissions, Set
zy
” One, propounded on Plaintiff Kevin Moda. Defendant also seeks an award of $935 in sanctions
25
ro
6 against Plaintiff and/or his counsel of record, Payman Taheri, Esq., for reasonable costs and
Ped
26
egy
per
27 expenses, including attorneys’ fees, incurred in obtaining the foregoing order.
28
1
MOTION TO DEEM REQUEST FOR ADMISSIONS ADMITTED
Preview
@ FILED Sup erior Court of California ountv of Los Anceles Shari Rosenthal, Esq. (State Bar No. 123083) Sharon S. Jeffrey, Esq. (State Bar No. 228149) JUN 28 2017 ia — Manning & Kass, Ellrod, Ramirez, Trester LLP Sherri R. v, ty tBAeCutive Officer/Clark 801 South Figueroa Street, 15" Floor By, Deputy Los Angeles, CA 90017 Tel: (213) 624-6900 Fax: (213) 624-6999 Attorneys for Defendants BRIVANLOU PACOIMA, LC, MAHIN HAKAK at SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 / 11 12 KEVIN MODA, Plaintiff, Case No. BC608383 (Hon. Maureen Duffy Lewis, Dept. 38] s NOTICE OF MOTION AND MOTION TO ‘ Vv. DEEM REQUEST FOR ADMISSIONS 13 ADMITTED; REQUEST FOR Bs BRIVANLOU PACOIMA, LC, MAHIN SANCTIONS; MEMORANDUM OF Qa 14 HAKAK, and DOES 1 -10, Inclusive, POINTS AND AUTHORITIES; 5s DECLARATION OF ROBERT P. WARGO 15 Defendants Date: August 14, 2017 16 Time: 9:30 AM 17 Dept: 38 Res No. 170627230419 18 Trial: 9/11/2017 19 20 TO PLAINTIFF AND HIS COUNSEL OF RECORD: 21 PLEASE TAKE NOTICE that on August 14, 2017, at 9:30 AM, or as soon thereafter as 22 the matter may be heard Department 38 of the.abpve-entitled Court, located at 111 North Hill 23 Street, Los Angeles, CA, 90012, Defendant Brivanlou Pacoima, LC, will, and hereby does, move 24 this Court for an order deeming admitted those matters set forth in Request for Admissions, Set zy ” One, propounded on Plaintiff Kevin Moda. Defendant also seeks an award of $935 in sanctions 25 ro 6 against Plaintiff and/or his counsel of record, Payman Taheri, Esq., for reasonable costs and Ped 26 egy per 27 expenses, including attorneys’ fees, incurred in obtaining the foregoing order. 28 1 MOTION TO DEEM REQUEST FOR ADMISSIONS ADMITTED