On April 22, 2022 a
Motion-Secondary
was filed
involving a dispute between
Campos, Haydee Cruz,
and
American Honda Motor Co., Inc.,
Does 1-10,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
KNIGHT LAW GROUP, LLP ELECTRONICALLY FILED (Autc >)
Roger Kimos (SBN 283 163) SUPERIOR COURT OF CALIFC >RNIA
r0gerk@knightlaw.com COUNTY OF SAN BERNARDIN o
Thach Tran (SBN 3 10800) 10/20/2023 3:25 PM
thacht@knightlaw.com
10250 Constellation B1Vd., Suite 2500
Los Angeles, CA 90067
Telephone: (310) 552-2250
Fax: (310) 552-7973
OOQONUl-hUJN
Attorneys for Plaintiff,
HAYDEE CRUZ CAMPOS
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
\D
HAYDEE CRUZ CAMPOS, Case No.2 CIVSB2208274
10
Unlimited Jurisdiction
11 Plaintiff,
DECLARATION OF THACH TRAN
12 VS- IN SUPPORT OF PLAINTIFF’S
OPPOSITION TO DEFENDANT’S
13 MOTION TO COMPEL
AMERICAN HONDA MOTOR CO., INC., a COMPLIANCE WITH VEHICLE
14 California Corporation, and DOES 1 through 1C INSPECTION; REQUEST FOR
inclusive,
SANCTIONS
15
Defendants.
16
Date: November 2, 2023
17 Time: 8:30 am.
Dept: $27
18
Trial Date: November 6, 2023
19
Action Filed: April 22, 2022
20
21
22
23
24
25
26
27
28 -1-
DECLARATION OF THACH TRAN IN SUPPORT OF PLAINTIFF’S LIMITED OPPOSITION TO
DEFENDANT’S MOTION
DECLARATION OF THACH TRAN
I, Thach Tran declare
,
as follows:
1. I am an attorney licensed t0 practice before all Courts 0f the State 0f California, at Knight
Law Group, LLP, attorneys 0f record for HAYDEE CRUZ CAMPOS (“Plaintiff”) in the above-
OOQONUl-hUJN
captioned matter.
2. I have personal knowledge 0f the facts set forth herein, and, if called t0 testify regarding
those matters, I could and would competently testify thereto except as t0 matters stated on
information and belief, and as to those matters, I believe them t0 be true based upon my review
\D
0f my firm’s files and records in this matter.
10 3. I submit this declaration in support 0f Plaintiff s Limited Opposition t0 Defendant’s
11 Motion t0 Compel Compliance of Vehicle Inspection.
12 4. On September 27, 2023, the parties completed the vehicle inspection. A true and correct
13 copy 0f the Parties’ meet and confer efforts is attached hereto as Exhibit A.
14 I declare under penalty 0f perjury under the laws 0f the State 0f California that the
15 foregoing is true and correct and that this declaration was executed on October 20, 2023 in Los
16 Angeles, California.
17
18
19
20
Thach Tran
21
22
23
24
25
26
27
28 -2-
DECLARATION OF THACH TRAN IN SUPPORT OF PLAINTIFF’S LIMITED OPPOSITION TO
DEFENDANT’S MOTION
Document Filed Date
October 20, 2023
Case Filing Date
April 22, 2022
Category
Breach of Contract/Warranty Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
KNIGHT LAW GROUP, LLP ELECTRONICALLY FILED (Autc >) Roger Kimos (SBN 283 163) SUPERIOR COURT OF CALIFC >RNIA r0gerk@knightlaw.com COUNTY OF SAN BERNARDIN o Thach Tran (SBN 3 10800) 10/20/2023 3:25 PM thacht@knightlaw.com 10250 Constellation B1Vd., Suite 2500 Los Angeles, CA 90067 Telephone: (310) 552-2250 Fax: (310) 552-7973 OOQONUl-hUJN Attorneys for Plaintiff, HAYDEE CRUZ CAMPOS SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO \D HAYDEE CRUZ CAMPOS, Case No.2 CIVSB2208274 10 Unlimited Jurisdiction 11 Plaintiff, DECLARATION OF THACH TRAN 12 VS- IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT’S 13 MOTION TO COMPEL AMERICAN HONDA MOTOR CO., INC., a COMPLIANCE WITH VEHICLE 14 California Corporation, and DOES 1 through 1C INSPECTION; REQUEST FOR inclusive, SANCTIONS 15 Defendants. 16 Date: November 2, 2023 17 Time: 8:30 am. Dept: $27 18 Trial Date: November 6, 2023 19 Action Filed: April 22, 2022 20 21 22 23 24 25 26 27 28 -1- DECLARATION OF THACH TRAN IN SUPPORT OF PLAINTIFF’S LIMITED OPPOSITION TO DEFENDANT’S MOTION DECLARATION OF THACH TRAN I, Thach Tran declare , as follows: 1. I am an attorney licensed t0 practice before all Courts 0f the State 0f California, at Knight Law Group, LLP, attorneys 0f record for HAYDEE CRUZ CAMPOS (“Plaintiff”) in the above- OOQONUl-hUJN captioned matter. 2. I have personal knowledge 0f the facts set forth herein, and, if called t0 testify regarding those matters, I could and would competently testify thereto except as t0 matters stated on information and belief, and as to those matters, I believe them t0 be true based upon my review \D 0f my firm’s files and records in this matter. 10 3. I submit this declaration in support 0f Plaintiff s Limited Opposition t0 Defendant’s 11 Motion t0 Compel Compliance of Vehicle Inspection. 12 4. On September 27, 2023, the parties completed the vehicle inspection. A true and correct 13 copy 0f the Parties’ meet and confer efforts is attached hereto as Exhibit A. 14 I declare under penalty 0f perjury under the laws 0f the State 0f California that the 15 foregoing is true and correct and that this declaration was executed on October 20, 2023 in Los 16 Angeles, California. 17 18 19 20 Thach Tran 21 22 23 24 25 26 27 28 -2- DECLARATION OF THACH TRAN IN SUPPORT OF PLAINTIFF’S LIMITED OPPOSITION TO DEFENDANT’S MOTION