On November 12, 2020 a
Order to Show Cause
was filed
involving a dispute between
Amador, Alma Rosa,
Amador, Alonso,
Amador, Annette,
Amador, Anthony,
Moran, Haydee,
and
Does 2 Through 50,
Kao Logistics, Inc.,
Keystone Automotive Operations, Inc.,
Martin, James Joseph,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
Colin M. Jones, Esq. SBN: 265628 F i ED
A. Ilyas Akbari, Esq. SBN: 228051 SUPERIOR cougr 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
WILSHIRE LAW FIRM SAN BERNARDQNO DISTRICT
3055 Wilshire Blvd., 12th Floor
Los Angeles, California 90010 FEB 16 2023
Tel.: (213) 381—9988
Fax: (213) 381-9989 BY p / .
Email: colinsteam@wilshirelawfirm.com LILIKNA MAnrstAL.
O(OQNmO'l-wa-A
DEPUTY
Attorneys for Plaintiffs,
SUPERIOR COURT FOR THE STATE 0F CALIFORNIA
COUNTY OF SAN BERNARDINO
ALMA ROSA AMADOR, individually and CASE NO.: CIVSB2025762
as the Administrator for the Estate of
.h—sAAA
ALONSO AMADOR; HAYDEE MORAN, Assignedfor All Purposes t0 Honorable Brian S.
an individual; ALONSO AMADOR, an McCarville — Dept. S30 - SBJC
#WNA
137
moor
PLO
12" 90010—1
individual; ANNETTE AMADOR, an
FIRM.
8M1. individual; ANTHONY AMADOR, an DECLARATION OF COLIN M. JONES,
CA
ESQ., RE: ORDER T0 CAUSE RE
LAW
individual,
DISMISSAL: PLAINTIFF COUNSEL’S
vwrsh'we
Angelas,
OI
A Plaintiffs,
WILSHIRE
3055
Los vs. FAILURE TO APPEAR AT TRIAL
READINESS CONFERENCE ON JANUARY
KAO LOGISTICS, INC., a company; 5, 2023
JAMES JOSEPH MARTIN, an individual;
DOES 1 through 50, inclusive.
Complaint Filed: 11/12/20
Trial Date: 12/12/22
Defendants.
I, Colin M. Jones, hereby declare:
NNNNNNNNN-‘A—‘d
mVO’Cfl-waAOCDmNOS
1. I am an attorney licensed to practice law in the State of California and am a
senior partner with Wilshire Law Firm, attorney for Plaintiffs herein. The following facts are
within my personal knowledge and if called as a witness, I could and would competently testify
thereto.
2. I am familiar with this case and the procedural history that led to the imposition
of Order to Show Cause: Dismissal by the Court. The parties were scheduled to appear for the
1
DECLARATION OF COLIN M. JONES, ESQ., RE: ORDER T0 CAUSE RE DISMISSAL: PLAINTIFF
COUNSEL’S FAILURE TO APPEAR AT TRIAL READINESS CONFERENCE ON JANUARY 5, 2023
\y \y
Trial Readiness Conference on January 5, 2023, at 8:30 A.M.
3. On January 4, 2023, Plaintiffs’ counsel served the Notice of Remote Appearance
to all parties. A true and correct copy of the following notice is attached hereto as Exhibit l.
4. On the morning of January 5, 2023, and approximately 5 minutes prior to the
hearing start time, while waiting to be connected remotely with the court, I talked to Ilyas
(OQNODU'I-kwN-i
Akbari. Our plan was that I was to inform the Court Ilyas Akbari was at the filing window to
file the trial document and to answer any questions the Court may have had as I was fully
prepared to appear as co-trial counsel.
5. However, I was never let in the Courtroom via Zoom. Out of abundance of
caution, Iemailed to all counsel at 8:34 A.M explaining the circumstances. A true and correct
copy of this email is attached hereto as Exhibit 2.
6. Plaintiffs’ counsel was ready for trial on January 5, 2023, and remain ready for
tn'al, and respectfully ask this Court not to sanction plaintiffs or their counsel for failing to
137
Floor
PLC
FIR".
12" 90010-1
appear, as we had a good-faith basis to believe that I would be brought into the hearing remotely
Hvd.
LAW
CA to start the hearing while Ilyas Akban' was physically filing the joint trial documents downstairs.
Wilshire
Angeles,
WILSHIRE I declare under penalty of perjury that the foregoing is true and correct.
3055
Los
Executed on January 26, 2023, at Los Angeles, California.
GNQU'I-th—‘OCDGNOJUI-bWN-‘O
NNNNNNNNNA—LAAAAAAAA
Colin M. Jones, Declarant
2
DECLARATION OF COLIN M. JONES, ESQ., RE: ORDER TO CAUSE RE DISMISSAL: PLAINTIFF
COUNSEL’S FAILURE TO APPEAR AT TRIAL READINESS CONFERENCE ON JANUARY 5, 2023
Preview
Colin M. Jones, Esq. SBN: 265628 F i ED A. Ilyas Akbari, Esq. SBN: 228051 SUPERIOR cougr 0F CALIFORNIA COUNTY 0F SAN BERNARDINO WILSHIRE LAW FIRM SAN BERNARDQNO DISTRICT 3055 Wilshire Blvd., 12th Floor Los Angeles, California 90010 FEB 16 2023 Tel.: (213) 381—9988 Fax: (213) 381-9989 BY p / . Email: colinsteam@wilshirelawfirm.com LILIKNA MAnrstAL. O(OQNmO'l-wa-A DEPUTY Attorneys for Plaintiffs, SUPERIOR COURT FOR THE STATE 0F CALIFORNIA COUNTY OF SAN BERNARDINO ALMA ROSA AMADOR, individually and CASE NO.: CIVSB2025762 as the Administrator for the Estate of .h—sAAA ALONSO AMADOR; HAYDEE MORAN, Assignedfor All Purposes t0 Honorable Brian S. an individual; ALONSO AMADOR, an McCarville — Dept. S30 - SBJC #WNA 137 moor PLO 12" 90010—1 individual; ANNETTE AMADOR, an FIRM. 8M1. individual; ANTHONY AMADOR, an DECLARATION OF COLIN M. JONES, CA ESQ., RE: ORDER T0 CAUSE RE LAW individual, DISMISSAL: PLAINTIFF COUNSEL’S vwrsh'we Angelas, OI A Plaintiffs, WILSHIRE 3055 Los vs. FAILURE TO APPEAR AT TRIAL READINESS CONFERENCE ON JANUARY KAO LOGISTICS, INC., a company; 5, 2023 JAMES JOSEPH MARTIN, an individual; DOES 1 through 50, inclusive. Complaint Filed: 11/12/20 Trial Date: 12/12/22 Defendants. I, Colin M. Jones, hereby declare: NNNNNNNNN-‘A—‘d mVO’Cfl-waAOCDmNOS 1. I am an attorney licensed to practice law in the State of California and am a senior partner with Wilshire Law Firm, attorney for Plaintiffs herein. The following facts are within my personal knowledge and if called as a witness, I could and would competently testify thereto. 2. I am familiar with this case and the procedural history that led to the imposition of Order to Show Cause: Dismissal by the Court. The parties were scheduled to appear for the 1 DECLARATION OF COLIN M. JONES, ESQ., RE: ORDER T0 CAUSE RE DISMISSAL: PLAINTIFF COUNSEL’S FAILURE TO APPEAR AT TRIAL READINESS CONFERENCE ON JANUARY 5, 2023 \y \y Trial Readiness Conference on January 5, 2023, at 8:30 A.M. 3. On January 4, 2023, Plaintiffs’ counsel served the Notice of Remote Appearance to all parties. A true and correct copy of the following notice is attached hereto as Exhibit l. 4. On the morning of January 5, 2023, and approximately 5 minutes prior to the hearing start time, while waiting to be connected remotely with the court, I talked to Ilyas (OQNODU'I-kwN-i Akbari. Our plan was that I was to inform the Court Ilyas Akbari was at the filing window to file the trial document and to answer any questions the Court may have had as I was fully prepared to appear as co-trial counsel. 5. However, I was never let in the Courtroom via Zoom. Out of abundance of caution, Iemailed to all counsel at 8:34 A.M explaining the circumstances. A true and correct copy of this email is attached hereto as Exhibit 2. 6. Plaintiffs’ counsel was ready for trial on January 5, 2023, and remain ready for tn'al, and respectfully ask this Court not to sanction plaintiffs or their counsel for failing to 137 Floor PLC FIR". 12" 90010-1 appear, as we had a good-faith basis to believe that I would be brought into the hearing remotely Hvd. LAW CA to start the hearing while Ilyas Akban' was physically filing the joint trial documents downstairs. Wilshire Angeles, WILSHIRE I declare under penalty of perjury that the foregoing is true and correct. 3055 Los Executed on January 26, 2023, at Los Angeles, California. GNQU'I-th—‘OCDGNOJUI-bWN-‘O NNNNNNNNNA—LAAAAAAAA Colin M. Jones, Declarant 2 DECLARATION OF COLIN M. JONES, ESQ., RE: ORDER TO CAUSE RE DISMISSAL: PLAINTIFF COUNSEL’S FAILURE TO APPEAR AT TRIAL READINESS CONFERENCE ON JANUARY 5, 2023