Preview
FILED
9/6/2022 3:50 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Dorothy Strogen DEPUTY
CAUSE NO. DC-22-08358
DR. ALLAN CRIBBINS III AND IN THE DISTRICT COURT
§§§§§§§§§§§
HEATHER CRRIBBINS,
PLAINTIFFS,
V. DALLAS COUNTY, TEXAS
HELIA BABAI AND FRED
KHARAZI,
DEFENDANTS. 192M) JUDICIAL DISTRICT
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION
TO REMOVE SUIT FROM EXPEDITED ACTIONS PROCESS
TO THE HONORABLE JUDGE OF SAID COURT
COME NOW Helia Babai and Fred Kharazi (“Defendants”) and file this Defendants’
Original Answer, Original Counterclaim and Motion to Remove Suit from Expedited Actions
Process, and would respectfully show the court the following:
I. DEFENDAN TS’ ORIGINAL ANSWER
A. General Denial
Defendants generally deny each and every, all and singular, the allegations contained in
Plaintiffs’ Original Petition (and any amendments or supplements thereto) and demands strict
proof thereof by a preponderance of the evidence.
B. Affirmative Defenses
Defendants assert the defense of lack of performance by Plaintiffs.
Defendants further assert the defense of unclean hands and bad faith.
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page l 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
II. COUNTER-PLAINTIFFS’ ORIGINAL COUNTERCLAIM
A. Parties
Counter-Plaintiff Helia Babai is an individual residing in Dallas county, Texas.
Counter-Plaintiff Fred Kharazi is an individual residing in Dallas County, Texas.
Counter-Defendant Dr. Allan Cribbins III is an individual residing at 14204 Hughes Lane,
Dallas, Texas. Counter-Defendant Dr. Allan Cribbins III has already appeared in this lawsuit.
Counter-Defendant Heather Cribbins is an individual residing at 14204 Hughes Lane,
Dallas, Texas. Counter-Defendant Heather Cribbins has already appeared in this lawsuit.
B. Factual Background
Plaintiffs Dr. Allan Cribbins III and Heather Cribbins (“Counter-Defendants”) and
Defendants Helia Babai and Fred Kharazi (“Counter-Plaintiffs”) entered into a Residential Lease
Agreement on May 10, 2021 for a short term lease of approximately seven months. (“Lease”) to
rent the property located at 6906 Wildglen Drive, Dallas. Texas 75230 (“Property”). The
occupants identified in the Lease included the two Counter-Defendants and their four teenage
children. The Lease further included a Pet Agreement authorizing four large dogs (two German
Shepherds, one Huskey and one Corgi) to stay at the Property, provided that among others,
Tenants/Counter-Defendants be liable for any damage to the Property or any item in the Property
caused by any pet.
Counter-Defendants vacated the Property as per the Lease Agreement in December 2021,
but left it with major damage and in dirty condition. Damages included, but were not limited to,
damage to toilets (two toilets clogged up), damage to pool lights (completely taken off and floating
on water), damage to items such as doorknobs missing, gas handle knob missing, damage to the
fountain (the second tier broken, causing the need to replace the fountain), damage to security
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 2 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
camera (broken), thermostat, H-Vac system and more. The foregoing damages far extended the
level of “normal wear and tear” generally acceptable in residential leases.
Counter-Plaintiffs sue Counter-Defendants for the damage caused to their Property.
C. Causes of Action
1) Breach of Contract
Counter-Plaintiffs incorporate the foregoing paragraphs herein and further allege that:
Counter-Defendants entered into a valid and enforceable written contract with the Counter-
Plaintiff. As per Section 16.A of the Lease, Counter-Defendants were required to surrender the
Property upon move-out, in the same condition as when received, except normal wear and tear.
Counter-Defendants materially breached the terms of the Lease by failing to surrender the
Property in the same condition and damaging the Property.
Counter-Defendants material breach of the Lease has actually and proximately caused
Counter-Plaintiffs monetary damages.
Counter-Plaintiffs seek to recover their monetary damages, attorney’s fees, pre/post-
judgment interest and costs and expenses of filing this counterclaim.
2) Declaratory Action
Counter-Plaintiffs pray that this Honorable Court declare that they were entitled to retain
the security deposit listed in the Lease to cover the damages caused by Counter-Defendants and
that Counter-Plaintiffs rightfully and lawfully retained the security deposit to cover their damages.
Counter-Plaintiffs further pray that this Court declare them entitled to recover the attorney’s fees
incurred in defending Counter-Defendants’ baseless claims and in bringing this counterclaim.
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 3 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
D. Claim for Relief
Counter-Plaintiffs seek monetary relief of $250,000 or less and non-monetary relief, as per
Rule 47(c)(2) of Texas Rules of Civil Procedure.
E. Attorney’s Fees
Because of Counter-Defendants’ conduct, Counter-Plaintiffs have been compelled to
engage the services of attorneys to prosecute their claims. Counter-Plaintiffs are entitled to recover
a reasonable sum for the necessary services of the attorneys in preparation and trial of this action
and for any appeals thereto pursuant to Chapters 37 and 38 of Texas Civil Practice and Remedies
Code.
III. MOTION TO REMOVE THE SUIT FROM THE EXPEDITED ACTIONS
PROCESS
Counter-Plaintiffs hereby file this Motion to Remove the Suit from the Expedited Actions Process
(“Motion”) and would respectfully show onto the Court the following:
A. Procedural Facts
Plaintiffs filed their Original Petition under Discovery Level 1, and further seeking only
monetary relief of $250,000 or less.
Plaintiffs’ Original Petition therefore invokes the Expedited Actions provided for in Rule
169 of Texas Rules of Civil Procedure.
Counter-Plaintiffsmefendants have, concurrently with this Motion filed a Counterclaim
against Plaintiffs which includes a breach of contract and also a declaratory judgment causes of
action. Counter-Plaintiffs/Defendants are therefore seeking a relief, other than monetary damages.
Furthermore, discovery in this matter is likely to include deposition of several witnesses
and a more extensive written discovery.
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 4 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
Counter-Plaintiffs therefore ask that this Honorable Court issue an order removing the suit
from the expedited actions process, and order that discovery be conducted under Level 2.
B. Arguments and Authorities:
Rule 169 of Texas Rules of Civil Procedure reads:
“(1)Application. The expedited actions process in this rule applies to a suit in which all claimants, other
than counter-claimants, afiirmatively plead that they seek only monetary relief aggregating $250,000 or
less, excluding interest, statutory or punitive damages and penalties, and attorney fees and costs.
(b) Recovery. In no event may a party who prosecutes a suit under this rule recover a judgment in excess
of $25 0, 000, excluding interest, statutory or punitive damages and penalties, and attorney fees and costs.
(c) Removal from Process.
(I) A court must remove a suit from the expedited actions process:
(A) 0n motion and a showing of good cause by any party; or
(B) if any claimant, other than a a
counter-claimant, files pleading or an amended or supplemental
pleading that seeks any relief other than the monetary relief allowed by (a).
(2) A pleading, amended pleading, or supplemental pleading that removes a suitfrom the expedited actions
process may not be filed without leave of court unless it is filed before the earlier of 30 days after the
discovery period is closed or 3 0 days before the date set for trial. Leave to amend may be granted only if
good cause for filing the pleading outweighs any prejudice to an opposing party.
(3) If a suit is removed from the expedited actions process, the court must reopen discovery under Rule
190.2(c).
(d) Expedited Actions Process:
(I) Discovery. Discovery is governed by Rule 190.2.
(2) Trial Setting; Continuances. 0n any party’s request, the court must set the case for a trial date that is
within 90 days after the discovery period in Rule I90.2(b)(1) ends. The court may continue the case twice,
not to exceed a total of 60 days.
(3) Time Limits for Trial. Each side is allowed no more than eight hours to complete jury selection,
opening statements, presentation of evidence, examination and cross-examination of witnesses, and
closing arguments. 0n motion and a showing ofgood cause by any party, the court may extend the time
limit to no more than twelve hours per side.
(A) The term "side" has the same definition set out in Rule 233.
(B) Time spent on objections, bench conferences, bills
” of exception,
and challenges for cause to a juror
under Rule 228 are not included in the time limit.
In this matter, Counter-Plaintiffs have filed their Original Counterclaim seeking a
declaratory judgment, which is a non-monetary relief. Furthermore, Counter-Plaintiffs expect to
conduct extensive oral and written discovery to determine the facts surrounding this matter and to
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 5 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
establish their claims and fulther defenses. As such, the level 1 discovery limitations will most
likely cause prejudice to Counter-Plaintiffs.
As such, Defendants pray that this Honorable Court removes the suit from the expedited
actions process and orders that discovery be conducted under Level 2 and in accordance with the
Rule 190.3 of Texas Rules of Civil Procedure.
II. PRAYER
Defendants pray for the following relief:
A. Plaintiffs takes nothing on Plaintiffs’ claims; and,
B. Counter-Plaintiffs’ economic damages;
C. Counter-Plaintiffs be declared entitled to retain the Security
Deposit;
D. Counter-Plaintiffs’ reasonable attorney’s fees;
E. Cost of court;
F. Pre and post judgment interest at the maximum legal rate;
G. Order removing the suit from expedited actions process;
H. Order to modify discovery level to level 2;
I. And for such other and further relief, at law or in equity, to which Counter-
Plaintiffs will be justly entitled.
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 6 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
Respectfully Submitted,
CHALAKI LAW, P.C.
By: /s/ Shawn S. Hashemi
E-Service: efi1e@cha1akilaw.com
Shawn Hashemi
Texas Bar No. 24090151
Yasamin Moussavi
Texas Bar No. 24128646
Sean Chalaki
Texas Bar No. 24072032
3234 Commander Drive, Suite 100
Carrollton, Texas 75006
Tel. (972) 793-8500
Fax. (800) 991-6288
ATTORNEYS FOR DEFENDANTS/
COUNTER-PLAINTIFFS
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 7 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
CERTIFICATE OF SERVICE
The undersigned does hereby certify that on the 6‘11 day of September, 2022, a true and
correct copy of the above and foregoing document was forwarded to counsel of record, Via
electronic service, in accordance with the Texas Rules of Civil Procedure.
/s/ Shawn Hashemz‘
Shawn Hashemi
DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 8 0f 8
TO REMOVE SUIT FROM EXPEDITED ACTIONS
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Envelope ID: 68013430
Status as of 9/7/2022 11:47 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Jeffrey Mills jeff.mills@wickphillips.com 9/7/2022 11:07:47 AM SENT
Ryan Carter ryan.carter@wickphi|lips.com 9/7/2022 11:07:47 AM SENT
Barb Morgan barb.morgan@wickphi|lips.com 9/7/2022 11:07:47 AM SENT
Camille Youngblood camille.youngblood@wickphillips.com 9/7/2022 11:07:47 AM SENT
Shawn Hashemi efile@chalakilaw.com 9/7/2022 11:07:47 AM SENT
Preview
FILED 9/6/2022 3:50 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Dorothy Strogen DEPUTY CAUSE NO. DC-22-08358 DR. ALLAN CRIBBINS III AND IN THE DISTRICT COURT §§§§§§§§§§§ HEATHER CRRIBBINS, PLAINTIFFS, V. DALLAS COUNTY, TEXAS HELIA BABAI AND FRED KHARAZI, DEFENDANTS. 192M) JUDICIAL DISTRICT DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION TO REMOVE SUIT FROM EXPEDITED ACTIONS PROCESS TO THE HONORABLE JUDGE OF SAID COURT COME NOW Helia Babai and Fred Kharazi (“Defendants”) and file this Defendants’ Original Answer, Original Counterclaim and Motion to Remove Suit from Expedited Actions Process, and would respectfully show the court the following: I. DEFENDAN TS’ ORIGINAL ANSWER A. General Denial Defendants generally deny each and every, all and singular, the allegations contained in Plaintiffs’ Original Petition (and any amendments or supplements thereto) and demands strict proof thereof by a preponderance of the evidence. B. Affirmative Defenses Defendants assert the defense of lack of performance by Plaintiffs. Defendants further assert the defense of unclean hands and bad faith. DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page l 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS II. COUNTER-PLAINTIFFS’ ORIGINAL COUNTERCLAIM A. Parties Counter-Plaintiff Helia Babai is an individual residing in Dallas county, Texas. Counter-Plaintiff Fred Kharazi is an individual residing in Dallas County, Texas. Counter-Defendant Dr. Allan Cribbins III is an individual residing at 14204 Hughes Lane, Dallas, Texas. Counter-Defendant Dr. Allan Cribbins III has already appeared in this lawsuit. Counter-Defendant Heather Cribbins is an individual residing at 14204 Hughes Lane, Dallas, Texas. Counter-Defendant Heather Cribbins has already appeared in this lawsuit. B. Factual Background Plaintiffs Dr. Allan Cribbins III and Heather Cribbins (“Counter-Defendants”) and Defendants Helia Babai and Fred Kharazi (“Counter-Plaintiffs”) entered into a Residential Lease Agreement on May 10, 2021 for a short term lease of approximately seven months. (“Lease”) to rent the property located at 6906 Wildglen Drive, Dallas. Texas 75230 (“Property”). The occupants identified in the Lease included the two Counter-Defendants and their four teenage children. The Lease further included a Pet Agreement authorizing four large dogs (two German Shepherds, one Huskey and one Corgi) to stay at the Property, provided that among others, Tenants/Counter-Defendants be liable for any damage to the Property or any item in the Property caused by any pet. Counter-Defendants vacated the Property as per the Lease Agreement in December 2021, but left it with major damage and in dirty condition. Damages included, but were not limited to, damage to toilets (two toilets clogged up), damage to pool lights (completely taken off and floating on water), damage to items such as doorknobs missing, gas handle knob missing, damage to the fountain (the second tier broken, causing the need to replace the fountain), damage to security DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 2 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS camera (broken), thermostat, H-Vac system and more. The foregoing damages far extended the level of “normal wear and tear” generally acceptable in residential leases. Counter-Plaintiffs sue Counter-Defendants for the damage caused to their Property. C. Causes of Action 1) Breach of Contract Counter-Plaintiffs incorporate the foregoing paragraphs herein and further allege that: Counter-Defendants entered into a valid and enforceable written contract with the Counter- Plaintiff. As per Section 16.A of the Lease, Counter-Defendants were required to surrender the Property upon move-out, in the same condition as when received, except normal wear and tear. Counter-Defendants materially breached the terms of the Lease by failing to surrender the Property in the same condition and damaging the Property. Counter-Defendants material breach of the Lease has actually and proximately caused Counter-Plaintiffs monetary damages. Counter-Plaintiffs seek to recover their monetary damages, attorney’s fees, pre/post- judgment interest and costs and expenses of filing this counterclaim. 2) Declaratory Action Counter-Plaintiffs pray that this Honorable Court declare that they were entitled to retain the security deposit listed in the Lease to cover the damages caused by Counter-Defendants and that Counter-Plaintiffs rightfully and lawfully retained the security deposit to cover their damages. Counter-Plaintiffs further pray that this Court declare them entitled to recover the attorney’s fees incurred in defending Counter-Defendants’ baseless claims and in bringing this counterclaim. DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 3 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS D. Claim for Relief Counter-Plaintiffs seek monetary relief of $250,000 or less and non-monetary relief, as per Rule 47(c)(2) of Texas Rules of Civil Procedure. E. Attorney’s Fees Because of Counter-Defendants’ conduct, Counter-Plaintiffs have been compelled to engage the services of attorneys to prosecute their claims. Counter-Plaintiffs are entitled to recover a reasonable sum for the necessary services of the attorneys in preparation and trial of this action and for any appeals thereto pursuant to Chapters 37 and 38 of Texas Civil Practice and Remedies Code. III. MOTION TO REMOVE THE SUIT FROM THE EXPEDITED ACTIONS PROCESS Counter-Plaintiffs hereby file this Motion to Remove the Suit from the Expedited Actions Process (“Motion”) and would respectfully show onto the Court the following: A. Procedural Facts Plaintiffs filed their Original Petition under Discovery Level 1, and further seeking only monetary relief of $250,000 or less. Plaintiffs’ Original Petition therefore invokes the Expedited Actions provided for in Rule 169 of Texas Rules of Civil Procedure. Counter-Plaintiffsmefendants have, concurrently with this Motion filed a Counterclaim against Plaintiffs which includes a breach of contract and also a declaratory judgment causes of action. Counter-Plaintiffs/Defendants are therefore seeking a relief, other than monetary damages. Furthermore, discovery in this matter is likely to include deposition of several witnesses and a more extensive written discovery. DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 4 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS Counter-Plaintiffs therefore ask that this Honorable Court issue an order removing the suit from the expedited actions process, and order that discovery be conducted under Level 2. B. Arguments and Authorities: Rule 169 of Texas Rules of Civil Procedure reads: “(1)Application. The expedited actions process in this rule applies to a suit in which all claimants, other than counter-claimants, afiirmatively plead that they seek only monetary relief aggregating $250,000 or less, excluding interest, statutory or punitive damages and penalties, and attorney fees and costs. (b) Recovery. In no event may a party who prosecutes a suit under this rule recover a judgment in excess of $25 0, 000, excluding interest, statutory or punitive damages and penalties, and attorney fees and costs. (c) Removal from Process. (I) A court must remove a suit from the expedited actions process: (A) 0n motion and a showing of good cause by any party; or (B) if any claimant, other than a a counter-claimant, files pleading or an amended or supplemental pleading that seeks any relief other than the monetary relief allowed by (a). (2) A pleading, amended pleading, or supplemental pleading that removes a suitfrom the expedited actions process may not be filed without leave of court unless it is filed before the earlier of 30 days after the discovery period is closed or 3 0 days before the date set for trial. Leave to amend may be granted only if good cause for filing the pleading outweighs any prejudice to an opposing party. (3) If a suit is removed from the expedited actions process, the court must reopen discovery under Rule 190.2(c). (d) Expedited Actions Process: (I) Discovery. Discovery is governed by Rule 190.2. (2) Trial Setting; Continuances. 0n any party’s request, the court must set the case for a trial date that is within 90 days after the discovery period in Rule I90.2(b)(1) ends. The court may continue the case twice, not to exceed a total of 60 days. (3) Time Limits for Trial. Each side is allowed no more than eight hours to complete jury selection, opening statements, presentation of evidence, examination and cross-examination of witnesses, and closing arguments. 0n motion and a showing ofgood cause by any party, the court may extend the time limit to no more than twelve hours per side. (A) The term "side" has the same definition set out in Rule 233. (B) Time spent on objections, bench conferences, bills ” of exception, and challenges for cause to a juror under Rule 228 are not included in the time limit. In this matter, Counter-Plaintiffs have filed their Original Counterclaim seeking a declaratory judgment, which is a non-monetary relief. Furthermore, Counter-Plaintiffs expect to conduct extensive oral and written discovery to determine the facts surrounding this matter and to DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 5 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS establish their claims and fulther defenses. As such, the level 1 discovery limitations will most likely cause prejudice to Counter-Plaintiffs. As such, Defendants pray that this Honorable Court removes the suit from the expedited actions process and orders that discovery be conducted under Level 2 and in accordance with the Rule 190.3 of Texas Rules of Civil Procedure. II. PRAYER Defendants pray for the following relief: A. Plaintiffs takes nothing on Plaintiffs’ claims; and, B. Counter-Plaintiffs’ economic damages; C. Counter-Plaintiffs be declared entitled to retain the Security Deposit; D. Counter-Plaintiffs’ reasonable attorney’s fees; E. Cost of court; F. Pre and post judgment interest at the maximum legal rate; G. Order removing the suit from expedited actions process; H. Order to modify discovery level to level 2; I. And for such other and further relief, at law or in equity, to which Counter- Plaintiffs will be justly entitled. DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 6 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS Respectfully Submitted, CHALAKI LAW, P.C. By: /s/ Shawn S. Hashemi E-Service: efi1e@cha1akilaw.com Shawn Hashemi Texas Bar No. 24090151 Yasamin Moussavi Texas Bar No. 24128646 Sean Chalaki Texas Bar No. 24072032 3234 Commander Drive, Suite 100 Carrollton, Texas 75006 Tel. (972) 793-8500 Fax. (800) 991-6288 ATTORNEYS FOR DEFENDANTS/ COUNTER-PLAINTIFFS DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 7 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS CERTIFICATE OF SERVICE The undersigned does hereby certify that on the 6‘11 day of September, 2022, a true and correct copy of the above and foregoing document was forwarded to counsel of record, Via electronic service, in accordance with the Texas Rules of Civil Procedure. /s/ Shawn Hashemz‘ Shawn Hashemi DEFENDANTS’ ORIGINAL ANSWER, ORIGINAL COUNTERCLAIM AND MOTION Page 8 0f 8 TO REMOVE SUIT FROM EXPEDITED ACTIONS Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Envelope ID: 68013430 Status as of 9/7/2022 11:47 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jeffrey Mills jeff.mills@wickphillips.com 9/7/2022 11:07:47 AM SENT Ryan Carter ryan.carter@wickphi|lips.com 9/7/2022 11:07:47 AM SENT Barb Morgan barb.morgan@wickphi|lips.com 9/7/2022 11:07:47 AM SENT Camille Youngblood camille.youngblood@wickphillips.com 9/7/2022 11:07:47 AM SENT Shawn Hashemi efile@chalakilaw.com 9/7/2022 11:07:47 AM SENT