On May 23, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Berger Bruce,
and
K-Cars Inc.,
Western Surety Company,
for Other Contract Dispute (not breach/insurance/fraud/negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
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Robert B. Mobasseri (SBN 193193) Los Angeles Superior Court ss
Amy L. Hajduk (SBN 230211) Pe)
Law Offices of Robert B. Mobasseri, PC =
515 S. Figueroa Street, Suite 1200
JUL -6 2016 his
pe
Los Angeles, CA 90071 ner Eneeuiivg GbieaHbterk
Tel: 213-282-2000 eS Bepuly
Fax: 213-282-3000
Attorneys for Plaintiff Bruce Berger
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
10
11 BRUCE BERGER, an individual; Case No.: BC509795
Complaint filed: May 23, 2013
12 Plaintiff,
13 vs. PLAINTIFF’S REPLY IN SUPPORT OF
MOTION TO AMEND JUDGMENT
14 K-CARS, INC., a California corporation;
WESTERN SURETY COMPANY, a South Date: July 13, 2006
15 Dakota corporation; DOES 1 through S0, Time: 10:00 a.m.
16 Inclusive, Dept.: 71
17 RES. ID 160407118707
Defendants.
18
19 Plaintiff Bruce Berger submits this Reply memorandum in support of his motion to
20 amend judgment to add K-Kars, Inc., a California corporation, as a judgment debtor.
21 I SUMMARY
22 K-Kars, Inc., the entity which Plaintiff seeks to add as a judgment debtor, has filed aj
23 substantive Opposition on the merits. The Opposition, based on the Declaration of Sean Garib
24 lacks any documentary corroboration of its various contentions. For example, despite claiming!
25 that he invested $1,500,000 of new capital into K-Kars, Inc., Mr. Garib does not provide any|
documentary evidence of this investment.
sad
2 What the Declaration does establish is that the “new” K-Kars, Inc. business is a mirror
image of the old, purportedly-insolvent business known as K-Cars, Inc.:
PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO AMEND JUDGMENT
1
Document Filed Date
July 06, 2016
Case Filing Date
May 23, 2013
Category
Other Contract Dispute (not breach/insurance/fraud/negligence) (General Jurisdiction)
Status
Default Judgment By Court - Before Trial 01/27/2014
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@ e S&S cA} mee Robert B. Mobasseri (SBN 193193) Los Angeles Superior Court ss Amy L. Hajduk (SBN 230211) Pe) Law Offices of Robert B. Mobasseri, PC = 515 S. Figueroa Street, Suite 1200 JUL -6 2016 his pe Los Angeles, CA 90071 ner Eneeuiivg GbieaHbterk Tel: 213-282-2000 eS Bepuly Fax: 213-282-3000 Attorneys for Plaintiff Bruce Berger IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 10 11 BRUCE BERGER, an individual; Case No.: BC509795 Complaint filed: May 23, 2013 12 Plaintiff, 13 vs. PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO AMEND JUDGMENT 14 K-CARS, INC., a California corporation; WESTERN SURETY COMPANY, a South Date: July 13, 2006 15 Dakota corporation; DOES 1 through S0, Time: 10:00 a.m. 16 Inclusive, Dept.: 71 17 RES. ID 160407118707 Defendants. 18 19 Plaintiff Bruce Berger submits this Reply memorandum in support of his motion to 20 amend judgment to add K-Kars, Inc., a California corporation, as a judgment debtor. 21 I SUMMARY 22 K-Kars, Inc., the entity which Plaintiff seeks to add as a judgment debtor, has filed aj 23 substantive Opposition on the merits. The Opposition, based on the Declaration of Sean Garib 24 lacks any documentary corroboration of its various contentions. For example, despite claiming! 25 that he invested $1,500,000 of new capital into K-Kars, Inc., Mr. Garib does not provide any| documentary evidence of this investment. sad 2 What the Declaration does establish is that the “new” K-Kars, Inc. business is a mirror image of the old, purportedly-insolvent business known as K-Cars, Inc.: PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO AMEND JUDGMENT 1