Preview
\r \a
Joseph Lavi, Esq. (SBN 209776)
jlavi@lelawfirm.com
Vincent C. Granberry, Esq. (SBN 276483)
F LE D
2W
Vgranbem@lelawfirm.com SUPEMOR COURT 0F
I
CAUFORNIA
Anwar D' Burton’ Esq' (SBN 25 3504)
aburton@lea1awfirm.com CSXSLE Q&Aséwfggvggo‘go
a
Pooja V. Patel, Esq. (SBN 317891)
MAY 1 9 2021
LAVI & EBRAHIMIAN, LLP
8889 W. Olympic B1Vd., Suite 200
Beverly Hills, California 90211 W ~
OR‘A M PORT,,V_.MOV
DEPUTY"
Telephone: (310) 432-0000 '
"
Facsimile: (310) 432-0001
Attorneys for PLAINTIFF JEFFREY
MADDIES,
d.
on behalf of himself and others similarly situate
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO
11
12
behalf of himself and Case No.: CIVDSI919776
JEFFREY MADDIES, on
13 others similarly situated,
CLASS ACTION
14 PLAINTIFF,
[Assignedfor allpurposes t0 the Hon. David
15 VS' Cohn; Dept. 5—26]
16
and DOES to DECLARATION OF POOJA V. PATEL IN
GOLIATH FINANCIAL, INQ; 1
SUPPORT 0F PLAINTIFF JEFFREY
100, inclusive,
17
MADDIEs’s MOTION T0 COMPEL
18
DEFENDANTS- DEFENDANT GOLIATH FINANCIAL,
INC.’S FURTHER RESPONSES TO
PLAINTIFF'S REQUEST FOR SPECIAL
A8 19
20
INTERROGATORIES, SET ONE;
EXHIBITS
21
[Filed concurrently with the Notice ofMotion
”3.5 22
and Motion t0 Compel; Separate Statement in
support thereof; and [Proposed] Order]
} 23
24
HEARING INFORMATION:
Date: July 6, 2021
Time: 10:00 a.m.
25 Dept: 826
26
27
Y MADDIES’S MOTION TO COMPEL
28 DECLARATION OF POOJA V. PATEL IN SUPPORT OF PLAINTIFF JEFFRE PLAINTIFF'S REQUESTS FOR SPECIAL
DEFENDANT GOLIAT H FINANC IAL, INC.’S FURTH ER RESPON SES TO
INTERROGATORIES, SET ONE
l
\r \v
DECLARATION OF POOJA V. PATEL
to practice law before all the courts of the State of
1. I am an attorney at law duly authorized
California. I am an associate attorney at the Law Firm of Lavi & Ebrahimian, LLP and one of the
JEFFREY MADDIES in this case. I am familiar with the files,
attorneys of record for Plaintiff
testify to the following facts on
could and would competently
pleadings, and facts in this case and
my own personal knowledge or information and
belief.
the basis of
action matter. This Motion is necessary because Defendant
2. This is a wage and hour class
rather than
ly respond to basic discovery. Specifically,
Goliath Financial, Inc. has failed to preper
ery, despite
ses, Defendant provided boilerplate discov
attempting t0 provide any substantive respon
many requests to do so.
10
Request for Special Interrogatories, Set One
to
3- The discovery at issue is Plaintiff‘s
11
ing this
Inc. Plaintiff has met and conferred with Defendant regard
12 Defendant Goliath Financial
ble
discovery issue, including participating in
two informal discovery conference with the Honora
13
14 David Cohn, and was left with no choice but to file motions.
l Interrogatories, Set One.
4. On October 15, 2021, Plaintiffpropounded Request for Specia
15
gatories, Set
Attached as Exhibit 1 is a true and correct copy of Plaintiff s Request for Special Interro
l6
One.
m
17
, a two—week
5. On November l9, 2021, Defendant requested, and Plaintiff granted
18
l Interrogatories, Set One. Attached as
extension to respond to Plaintiff” s Request for Specia
19
a true and correct copy of Defendant’s request for a two-week extension.
g is
20
on December 2021, Defendant served all objections to Plaintiff’s
6. Two weeks later, 3,
21
as Exhibit 3 a true and correct copy of
Request for Special Interrogatories, Set One. Attached
is
22
gatories, Set One.
Defendant’s Responses to Plaintiffs Request for Special Interro
23
ion 0f the same
7. On December 28, 2020, as Defendant’s response was merely a repetit
24
no substantive responses, Plaintiff requested Defendant t0 supplement their
obj ections with
25 request.
2021. Attached as Exhibit 4 is a true and correct copy 0f Plaintiff’s
responses by January 4,
26 in an informal
8. On January 13, 2021, Plaintiff suggested that the Parties participate
27
discovery conference. 2021, after sending two emails requesting a response,
On January 15,
Y MADDIES’S MOTION TO COMPEL
28 DECLARATION OF POOJA V. PATEL IN SUPPORT OF PLAINTIFF JEFFRE
PLAINTIFF'S SPECIAL INTERROGATORIES,
DEFENDANT GOLIAT H FINANC IAL, INC.’S FURTH ER RESPON SES TO
SET ONE
2
Preview
\r \a Joseph Lavi, Esq. (SBN 209776) jlavi@lelawfirm.com Vincent C. Granberry, Esq. (SBN 276483) F LE D 2W Vgranbem@lelawfirm.com SUPEMOR COURT 0F I CAUFORNIA Anwar D' Burton’ Esq' (SBN 25 3504) aburton@lea1awfirm.com CSXSLE Q&Aséwfggvggo‘go a Pooja V. Patel, Esq. (SBN 317891) MAY 1 9 2021 LAVI & EBRAHIMIAN, LLP 8889 W. Olympic B1Vd., Suite 200 Beverly Hills, California 90211 W ~ OR‘A M PORT,,V_.MOV DEPUTY" Telephone: (310) 432-0000 ' " Facsimile: (310) 432-0001 Attorneys for PLAINTIFF JEFFREY MADDIES, d. on behalf of himself and others similarly situate SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 12 behalf of himself and Case No.: CIVDSI919776 JEFFREY MADDIES, on 13 others similarly situated, CLASS ACTION 14 PLAINTIFF, [Assignedfor allpurposes t0 the Hon. David 15 VS' Cohn; Dept. 5—26] 16 and DOES to DECLARATION OF POOJA V. PATEL IN GOLIATH FINANCIAL, INQ; 1 SUPPORT 0F PLAINTIFF JEFFREY 100, inclusive, 17 MADDIEs’s MOTION T0 COMPEL 18 DEFENDANTS- DEFENDANT GOLIATH FINANCIAL, INC.’S FURTHER RESPONSES TO PLAINTIFF'S REQUEST FOR SPECIAL A8 19 20 INTERROGATORIES, SET ONE; EXHIBITS 21 [Filed concurrently with the Notice ofMotion ”3.5 22 and Motion t0 Compel; Separate Statement in support thereof; and [Proposed] Order] } 23 24 HEARING INFORMATION: Date: July 6, 2021 Time: 10:00 a.m. 25 Dept: 826 26 27 Y MADDIES’S MOTION TO COMPEL 28 DECLARATION OF POOJA V. PATEL IN SUPPORT OF PLAINTIFF JEFFRE PLAINTIFF'S REQUESTS FOR SPECIAL DEFENDANT GOLIAT H FINANC IAL, INC.’S FURTH ER RESPON SES TO INTERROGATORIES, SET ONE l \r \v DECLARATION OF POOJA V. PATEL to practice law before all the courts of the State of 1. I am an attorney at law duly authorized California. I am an associate attorney at the Law Firm of Lavi & Ebrahimian, LLP and one of the JEFFREY MADDIES in this case. I am familiar with the files, attorneys of record for Plaintiff testify to the following facts on could and would competently pleadings, and facts in this case and my own personal knowledge or information and belief. the basis of action matter. This Motion is necessary because Defendant 2. This is a wage and hour class rather than ly respond to basic discovery. Specifically, Goliath Financial, Inc. has failed to preper ery, despite ses, Defendant provided boilerplate discov attempting t0 provide any substantive respon many requests to do so. 10 Request for Special Interrogatories, Set One to 3- The discovery at issue is Plaintiff‘s 11 ing this Inc. Plaintiff has met and conferred with Defendant regard 12 Defendant Goliath Financial ble discovery issue, including participating in two informal discovery conference with the Honora 13 14 David Cohn, and was left with no choice but to file motions. l Interrogatories, Set One. 4. On October 15, 2021, Plaintiffpropounded Request for Specia 15 gatories, Set Attached as Exhibit 1 is a true and correct copy of Plaintiff s Request for Special Interro l6 One. m 17 , a two—week 5. On November l9, 2021, Defendant requested, and Plaintiff granted 18 l Interrogatories, Set One. Attached as extension to respond to Plaintiff” s Request for Specia 19 a true and correct copy of Defendant’s request for a two-week extension. g is 20 on December 2021, Defendant served all objections to Plaintiff’s 6. Two weeks later, 3, 21 as Exhibit 3 a true and correct copy of Request for Special Interrogatories, Set One. Attached is 22 gatories, Set One. Defendant’s Responses to Plaintiffs Request for Special Interro 23 ion 0f the same 7. On December 28, 2020, as Defendant’s response was merely a repetit 24 no substantive responses, Plaintiff requested Defendant t0 supplement their obj ections with 25 request. 2021. Attached as Exhibit 4 is a true and correct copy 0f Plaintiff’s responses by January 4, 26 in an informal 8. On January 13, 2021, Plaintiff suggested that the Parties participate 27 discovery conference. 2021, after sending two emails requesting a response, On January 15, Y MADDIES’S MOTION TO COMPEL 28 DECLARATION OF POOJA V. PATEL IN SUPPORT OF PLAINTIFF JEFFRE PLAINTIFF'S SPECIAL INTERROGATORIES, DEFENDANT GOLIAT H FINANC IAL, INC.’S FURTH ER RESPON SES TO SET ONE 2