Conference: Motions to Compel Further Responses to Discovery

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                                Joseph Lavi. Esq. (SBN 209776)
     Vincent C. Granberry. Esq. (SBN 276483)                                        F   I   LE   D
     S. Phillip Song. Esq. (SBN 326572)                                 SUPERIOR counT 0F CALIFORNIA
     LAVI   & EBRAHIMIAN, LLP                                               coumv or SAN aenmnomo
     8889 W. Olympic Blvd.. Suite 200
     Beverly Hills, California 9021 l                                              AUG 02       2023
     Telephone: (310) 432-0000
     Facsimile: (310) 432-0001
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     Emails: ilavi’Zl‘lelawfirmxom
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            vgranbcrrx"[I‘lclawfirmxom
            psong’d lclawfi rm.com
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     Attorneys for PLAINTIFF JEFFREY MADDIES,                                                                      A8
     on behalf of himself and others similarly situated.
                                                                                                                   XVd

                               SUPERIOR COURT 0F THE STATE OF CALIFORNIA
                                       FOR THE COUNTY OF SAN BERNARDINO

     JEFFREY MADDIES. on                behalf of himself and        Case No.1 CIVDSI919776
     others similarly situated,

                                                                     CLASS ACTION
             PLAINTIFF.
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     vs.
                                                                     Hon. David Cohn; Dept. 5-26]
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     GOLIATH FINANCIAL, INC;                   and   DOES   l   to
                                                                     PLAINTIFF’S            REPORT IN ADVANCE OF
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     100. inclusive.                                                 STATUS CONFERNECE

             DEFENDANTS.                                             Statue Conference:
                                                                     Date: August 7, 2023
                                                                     Time:   8:30AM
                                                                     Dept. 5-26


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            Plaintiff   JEFFREY MADDIES              ("Plaintiff“),    by and through his counsel 0f record, hereby

     submits the following report        in   advance 0f the Status Conference on August           7,   2023. Plaintiff‘s

     counsel repeatedly reached out to Defendant         GOLIATH FINANCIAL. INC.‘S ("Defendant“) counsel
     via email and telephone, over the course of several months, t0 meet and confer regarding the case, the


     status conference,      and the joint   report. but Defendant‘s counsel refused to respond. Plaintiff was left


     with n0 choice but t0 file the status report unilaterally. with just Plaintiff’s position included within.

             Based on Defendant‘s alleged financial hardship.                  Plaintiff has attempted t0 negotiate an


     individual settlement. During telephonic         meet and confers. Defendant informed      Plaintiffthat   it   would

     produce the requested financial documents. Plaintiff has been following up regularly to obtain these

10   documents, as well as to begin negotiations on an individual settlement. To date. there has been no

11   progress on the production of financial records or individual settlement discussions; Defendant’s

12   counsel has become wholly unresponsive.

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     Dated: August      l.   2023                         Respectfully submitted.
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                                                          LAVI    & EBRAHIMIAN, LLP
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l7                                                        By.
                                                                             Klifl        V
                                                                  Josebfi Lavi. Esq.
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                                                                      Vincent C. Granberry, Esq.
                                                                      S. Phillip   Song. Esq.
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                                                                  Attorneys for Plaintiff Jeffrey Maddies
                                                                  and Other Class Members




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