Motion-Secondary: ODEH -V- FERNANDEZ Print

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                                Ali     Odeh                                                                            SUPER
                                                                                                       F' L E   D
     14167 Flamingo Bay Ln.                                                                   ngfigggmgégfikggfig"
                                                                                                     BERNARD'NO D'sm'CT
     Moreno Valley, California 92553
     Telephone: (815) 600-2550
                                                                                                     AUG 28   2023
     E-Mail: A,19275@yahgg.ggm



                                            SUPERIOR COURT 0F CALIF0%1A                                   “W    GUARDADO‘   Dewy


                                               COUNTY OF SAN BERNARDINO


     ALI ODEH,                                                           Case No.: CIVDSl 823772
                              ,    ,
                                                                         Honorable Judge John M. Pacheco
                         Plalntlfi‘,


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     vs'
                                                                         DECLARATION 0F ALI ODEH 1N
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     LYNGLADEN F E RN ANDEZ                         DDS‘ ET AL
                                                             .
                                                                         SUPPORT 0F EX PARTE APPLICATION
                                                '


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                                                                         FOR STAY 0F PROCEEDINGS. 0R
                         Defendants,                                     ALTERNATIVELY, CONTINUANCE 0F
14                                                                       TRIAL     DA'I‘E

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16                                                                 .
                                                                         HEARINQ DATE:
                                                                   '


                                                                         Date: AUGUST 28, 2023
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                                                                         Time:      8:30AM.
                                                                         Dept:      $31
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                                               D&ARATION 0F ALI ODEH
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               I,   ALI ODEH,          declare as follows:
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               1.        I   am   the plaintiff party in this action and         am a   self-represented litigant.


24             2.        I   make      this declaration in support Plaintiff‘s      EX PARTE APPLICATION TO
25   STAY PROCEEDINGS, OR ALTERNA'FIVEI.Y, CONTINUE TRIAL DATE for a period of at
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     least   120 days.
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28                                                               . 1 .




                                                     DECLARATION OF ALI ODEII

                                                       CASENO. CIVDSI823772
                                        ALI ODEH V    LflVGLADEN FERNANDEZ DDS, ET Al
                3.             I   am aware     that the State            Bar of California has filed an action against                      my    former


     counsel Vasurnath Vijayraghavan (“VASU”). The action                                             is   regarded as In the Matter of:


     Vasumath Vijayraghavan (“VASU”), No.                                  3 10372, State Bar Court, Hearing Department — Los


     Angeles, Case             Number SBC-22-O—30883                       (“State        Bar Case”). The          trial in this   action   is   scheduled


     to being    on August 26, 2023, just two days before                                  this above-entitled action is           scheduled for


     trial.   In that     trial.   I   am   listed as a witness to testify.                A   true   and correct copy of the Joint              Pretrial


     Statement filed by the parties to that action                            is   attached hereto as Exhibit “A”.


                4.             Since being treated             at   Defendant Lyngladen Fernandez, DDS, Kingsly Dcntistry’s
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     dental office,         I   have had constant medical complications and surgical procedures                                        in   attempt to
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     correct the problems.


l3              5.             On August        l7,   I   was informed by my                 treating physician that          my    medical

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     condition had gotten worse, and that                           l   would require        surgical procedures to          my     spine,   back and
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     neck area on August 22, 2023. that                          will    demand      a protracted recovery period.                 A true and correct
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     copy of the physician‘s notes and scheduled procedure                                      is    attached hereto as Exhibit “B".             I
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l8   underwent those procedures on                        this   same day and am               currently in recovery phase.            As pan of

l9   recovery,       I   am unable          to use either hand,           and unable to stand for prolonged periods.

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                6.             0n August        24. 2023, at approximately 7:55 p.m..                          I   sent electronic mail      message        to


     Jerry Akita, Defense Counsel for Defendant Lyngladen Fernandez.                                                DDS. Kingsly       Dentistry. at
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     his email address             iflital @gmail.com                    to inform     him      that   l    would move     this   coun on August        28,
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24   2023. at 8:30 A.M. of Department S31 of San Bemardino Superior Court located                                                     at   247 West

25   Third Street San Bemardino, California 924]                                  5, for   an order to stay proceedings, or alternatively,

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     a continuance of the September                       5,   2023      trial date.

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28                                                                                  .2.


                                                               DECLARATION OF ALI ODEII

                                                                    CASE N0. CIVDSI823772
                                             ALI   ODEH V. LWGIADl-LN flz‘lfNANDEZ.                         DDS. ET. AL