On March 08, 2019 a
Party Discovery
was filed
involving a dispute between
Zaman, Sajida,
and
Does 1-20,
Liqui-Box Corporation,
for (Wrongful Termination)
in the District Court of Sacramento County.
Preview
FILED/ENDORSED
1JOSHUA S. FALAKASSA (SBN: 295045)
AUG - 8 2022
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450 By:. p. Vue
Deputy Clerk
3 Los Angeles, Califomia 90067
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
6 LIBERTY MAN LAW, P.C.
1010 F Street, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12 COUNTY OF SACRAMENTO
13
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
14 RESERVATION ID: 2665219
Plaintiff,
15 NOTICE OF MOTION AND MOTION
vs. TO QUASH OR MODIFY THE SCOPE
16 OF SUBPOENA TO SACRAMENTO
LIQUI-BOX CORPORATION, and DOES
ORTHOPEDIC CENTER AND
17 through 20, inclusive, MONETARY SANCTIONS
18 Defendants.
Date: October 20, 2022
19 Time: 1:30pm
Dept.: 53 >-
20 Trial Date: September 12, 2022 CD
21
22
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
23
NOTICE IS HEREBY GIVEN that on October 20, 2022 at 1:30p.m., or as soon thereaftei
24
as the matter may be heard, in Department 53 this Court, located at the Hall of Justice, 813 6th
25
Street, Sacramento, Califomia 95814, Plaintiff Sajida Zaman ("Plaintiff) will, and hereby does,
26
move for an order quashing or modifying the scope of Defendant Liqui-Box Corporation's
27
("Defendanf) Deposition Subpoena for Production of Business Records to Sacramento
28
NOTICE OF MOTION AND MOTION TO QUASH OR MODIFY THE SCOPE OF SUBPOENA TO
SACRAMENTO ORTHOPEDIC CENTER AND MONETARY SANCTIONS
1 of 2
1 Orthopedic Center ("Subpoena"), and will further move this Court for an order of monetary
2 sanctions in the amount of $810.00. The motion will be made on the grounds that the subpoena
3 seeks medical records not directly relevant to Plaintiffs claims and invades Plaintiffs right to
4 privacy {Alch v. Superior Court (2008) 165 Cal.App.4th 1412; Hale v. Superior Court (1994) 28
.5 Cal.App.4th 1421), and as a result Defendant should be ordered to pay fees and costs as a monetary
6 sanction. (Code Civ. Proc. §§ 1987.2(a).)
7 The motion will be based on this Notice, Declaration of Arash S. Khosrowshahi, the
8 Memorandum of Points and Authorities, on the records and file herein, and on such evidence as
9 may be presented at the hearing of the motion.
10 Pursuant to Local Rule 1.06 (A), the court will make a tentative mling on the merits of this
11 matter by 2:00 p.m., the court day before the hearing. The complete text ofthe tentative mlings
12 for the department may be downloaded off the court's website. If the party does not have online
13 access, they may call the dedicated phone number for the department as referenced in the local
14 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
15 hearing and receive the tentative mling. If you do not call the court and the opposing party by 4:00
16 p.m. the court day before the hearing, no hearing will be held.
17 Dated: August 5, 2022 LIBERTY MAN LAW, P.C.
FALAKASSA LAW, P.C.
18
19
20 Arash S. Khosrowshahi
21 Joshua S. Falakassa
Attomeys for Plaintiff Sajida Zaman
22
23
24
25
26
27
28
NOTICE OF MOTION AND MOTION TO QUASH OR MODIFY THE SCOPE OF SUBPOENA TO
SACRAMENTO ORTHOPEDIC CENTER AND MONETARY SANCTIONS
2 of 2
Document Filed Date
August 08, 2022
Case Filing Date
March 08, 2019
Category
(Wrongful Termination)
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FILED/ENDORSED 1JOSHUA S. FALAKASSA (SBN: 295045) AUG - 8 2022 FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 By:. p. Vue Deputy Clerk 3 Los Angeles, Califomia 90067 Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 ARASH S. KHOSROWSHAHI (SBN: 293246) 6 LIBERTY MAN LAW, P.C. 1010 F Street, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 14 RESERVATION ID: 2665219 Plaintiff, 15 NOTICE OF MOTION AND MOTION vs. TO QUASH OR MODIFY THE SCOPE 16 OF SUBPOENA TO SACRAMENTO LIQUI-BOX CORPORATION, and DOES ORTHOPEDIC CENTER AND 17 through 20, inclusive, MONETARY SANCTIONS 18 Defendants. Date: October 20, 2022 19 Time: 1:30pm Dept.: 53 >- 20 Trial Date: September 12, 2022 CD 21 22 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 23 NOTICE IS HEREBY GIVEN that on October 20, 2022 at 1:30p.m., or as soon thereaftei 24 as the matter may be heard, in Department 53 this Court, located at the Hall of Justice, 813 6th 25 Street, Sacramento, Califomia 95814, Plaintiff Sajida Zaman ("Plaintiff) will, and hereby does, 26 move for an order quashing or modifying the scope of Defendant Liqui-Box Corporation's 27 ("Defendanf) Deposition Subpoena for Production of Business Records to Sacramento 28 NOTICE OF MOTION AND MOTION TO QUASH OR MODIFY THE SCOPE OF SUBPOENA TO SACRAMENTO ORTHOPEDIC CENTER AND MONETARY SANCTIONS 1 of 2 1 Orthopedic Center ("Subpoena"), and will further move this Court for an order of monetary 2 sanctions in the amount of $810.00. The motion will be made on the grounds that the subpoena 3 seeks medical records not directly relevant to Plaintiffs claims and invades Plaintiffs right to 4 privacy {Alch v. Superior Court (2008) 165 Cal.App.4th 1412; Hale v. Superior Court (1994) 28 .5 Cal.App.4th 1421), and as a result Defendant should be ordered to pay fees and costs as a monetary 6 sanction. (Code Civ. Proc. §§ 1987.2(a).) 7 The motion will be based on this Notice, Declaration of Arash S. Khosrowshahi, the 8 Memorandum of Points and Authorities, on the records and file herein, and on such evidence as 9 may be presented at the hearing of the motion. 10 Pursuant to Local Rule 1.06 (A), the court will make a tentative mling on the merits of this 11 matter by 2:00 p.m., the court day before the hearing. The complete text ofthe tentative mlings 12 for the department may be downloaded off the court's website. If the party does not have online 13 access, they may call the dedicated phone number for the department as referenced in the local 14 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the 15 hearing and receive the tentative mling. If you do not call the court and the opposing party by 4:00 16 p.m. the court day before the hearing, no hearing will be held. 17 Dated: August 5, 2022 LIBERTY MAN LAW, P.C. FALAKASSA LAW, P.C. 18 19 20 Arash S. Khosrowshahi 21 Joshua S. Falakassa Attomeys for Plaintiff Sajida Zaman 22 23 24 25 26 27 28 NOTICE OF MOTION AND MOTION TO QUASH OR MODIFY THE SCOPE OF SUBPOENA TO SACRAMENTO ORTHOPEDIC CENTER AND MONETARY SANCTIONS 2 of 2