On July 26, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Kingdom Of Sweden,
and
Does 1 To 20, Inclusive,
Nosrat, Amir Hossein,
for Other Collections Unlimited
in the District Court of San Bernardino County.
Preview
v ORIGINAL
Dana Delman, Esq. (SBN 167307)
DELMAN VUKMANOVIC LLP f: Y
L
19200 Von Karman Avenue Suite 600 SUPER'OR UGURT 0F
CALIFOR
Irv1ne. Callfomla 92612 SAUngEFQAfAiADPTNBOEg?JS§RR%NrO
Telephone: (949) 852-3590
OCT 1 6 2023
Facsimile: (213) 867—9923
Email: dana@delvuklaw.com
\OOO\IO\LIIJ>DJNt—' av /
Attorneys for Defendant Christopher Amir Nosrat ROBWKRéTZMEIEh, DEPUTY
FAX
SUPERIOR COURT OF THE STATE OF CALIFORNIA
BY FOR THE COUNTY OF SAN BERNARDINO
KINGDOM OF SWEDEN CASE NO. ClV SB 2216123
plaintiff, [Assigned for all purposes to Hon. Jeffrey R.
Erickson, Sl4]
DEFENDANT’S EX PARTE
APPLICATION FOR AN ORDER (1)
AMIR HOSSEIN NOSRAT aka CONTINUING HEARING 0N
CHRISTOPHER AMIR NOSRAT; and PLAINTIFF’S SUMMARY JUDGMENT
DOES t0 20. Inclusive,
1 MOTION; (2) CONTINUING THE FINAL
STATUS CONFERENCE AND TRIAL
Defendants DATES, AND ALL RELATED PRE—TRIAL
DEADLINES FOR 60 DAYS;
MEMORANDUM 0F POINTS AND
NNNNNNNNNh—r—Ir—Ip—‘t—‘HH—g—p—
OONQM$WN~OO%\IGM$WNHO AUTHORITIES AND DECLARATION 0F
DANA DELMAN AND CHRISTOPHER
AMIR NOSRAT IN SUPPORT THEREOF
[Separate Declaration Of Dana Delman Re:
Notice Filed Concurrently Herewithl
Hearing Date: October 17, 2023
Tlme: 8:30 AM $-2323_ 70802
Dept: $14
M00
Complaint Filed: Sept. 8, 2022
Trial Date: June 3, 2024
EX PARTE APPLICATION TO CONTINUE SUMMARY JUDGMENT HEARING AND TRIAL DATES
APPLICATION
Defendant Christopher Amir Nosrat hereby applies for an order: (1) continuing the hearing
on Plaintiff‘s motion for summary judgment scheduled for November l, 2023 for at least 60 days
and (2) continuing the final status conference, trial date and all related pretrial deadlines for at least
60 days or as soon thereafter as the Coun deems appropriate.
\OOONOUIbLNNH
Good cause exists for this application. The opposition to Plaintiff‘s summary judgment
motion is due on October 18, 2023. Defendant recently substituted in pro per due to the fact that his
former attorney, Allan Cate (“Cate”) failed to keep him informed about the case and failed to
propound any discovery since his retention in February 2023. Cate also did not inform Defendant
that the summary judgment motion was filed August 21, 2023, ten days afier it was served, which is
the same day Defendant notified Cate that the attomey-client relationship was terminated. (Nosrat
Dccl., W 5, 6.) During Catc’s representation of Defendant, Defendant was under the impression that
his former counsel did in fact propound such discovery based on Cate's representations to
Defendant. (Nosrat Decl., 1] 3.) Defendant attempted to bring this application last week, but his
counsel did not effectuate the filing properly. (Delman Decl., 11 2.)
Defendant did not become aware of the failure to propound any discovery until Cate
informed Defendant about Plaintiff‘s summary judgment motion on August 21, 2023. (Nosrat Dccl.,
NNNNNNNNNHu—w—np—n—nm—‘p—H 1] 5.) After learning about Cate‘s failure to propound discovery, Defendant understood that he was
WNOMAWN~OOWNOM#WN~O not being appropriately represented and immediately sought to retain another attorney. (Nosrat
Decl., W 5-7.) Defendant wants Dana Delman to represent him, but at this time Ms. Delman is only
able to appear on a limited scope basis for the purpose of seeking continuance of the summary
judgment motion and serving discovery. Ms. Delman has two jury trials staning on October 27 and
November 6, 2023. She does not have sufficient time to learn the case and to research and draft an
opposition to the summary judgment motion as currently scheduled. (Delman Decl., 11 2.)
Additionally, Ms. Delman served discovery on October 10, 2023 as she believes that she needs
Plaintiff‘s responses to use as evidence in support 0f the opposition. Defendant may also need to
find and retain a Swedish lawyer, as the contract at issue in this case is governed by Swedish law.
The issues are complex, as Defendant believes that California law may also apply.
1
EX PARTE APPLICATION T0 CONTINUE SUMMARY JUDGMENT HEARING AND TRIAL DATES
Document Filed Date
October 16, 2023
Case Filing Date
July 26, 2022
Category
Other Collections Unlimited
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v ORIGINAL Dana Delman, Esq. (SBN 167307) DELMAN VUKMANOVIC LLP f: Y L 19200 Von Karman Avenue Suite 600 SUPER'OR UGURT 0F CALIFOR Irv1ne. Callfomla 92612 SAUngEFQAfAiADPTNBOEg?JS§RR%NrO Telephone: (949) 852-3590 OCT 1 6 2023 Facsimile: (213) 867—9923 Email: dana@delvuklaw.com \OOO\IO\LIIJ>DJNt—' av / Attorneys for Defendant Christopher Amir Nosrat ROBWKRéTZMEIEh, DEPUTY FAX SUPERIOR COURT OF THE STATE OF CALIFORNIA BY FOR THE COUNTY OF SAN BERNARDINO KINGDOM OF SWEDEN CASE NO. ClV SB 2216123 plaintiff, [Assigned for all purposes to Hon. Jeffrey R. Erickson, Sl4] DEFENDANT’S EX PARTE APPLICATION FOR AN ORDER (1) AMIR HOSSEIN NOSRAT aka CONTINUING HEARING 0N CHRISTOPHER AMIR NOSRAT; and PLAINTIFF’S SUMMARY JUDGMENT DOES t0 20. Inclusive, 1 MOTION; (2) CONTINUING THE FINAL STATUS CONFERENCE AND TRIAL Defendants DATES, AND ALL RELATED PRE—TRIAL DEADLINES FOR 60 DAYS; MEMORANDUM 0F POINTS AND NNNNNNNNNh—r—Ir—Ip—‘t—‘HH—g—p— OONQM$WN~OO%\IGM$WNHO AUTHORITIES AND DECLARATION 0F DANA DELMAN AND CHRISTOPHER AMIR NOSRAT IN SUPPORT THEREOF [Separate Declaration Of Dana Delman Re: Notice Filed Concurrently Herewithl Hearing Date: October 17, 2023 Tlme: 8:30 AM $-2323_ 70802 Dept: $14 M00 Complaint Filed: Sept. 8, 2022 Trial Date: June 3, 2024 EX PARTE APPLICATION TO CONTINUE SUMMARY JUDGMENT HEARING AND TRIAL DATES APPLICATION Defendant Christopher Amir Nosrat hereby applies for an order: (1) continuing the hearing on Plaintiff‘s motion for summary judgment scheduled for November l, 2023 for at least 60 days and (2) continuing the final status conference, trial date and all related pretrial deadlines for at least 60 days or as soon thereafter as the Coun deems appropriate. \OOONOUIbLNNH Good cause exists for this application. The opposition to Plaintiff‘s summary judgment motion is due on October 18, 2023. Defendant recently substituted in pro per due to the fact that his former attorney, Allan Cate (“Cate”) failed to keep him informed about the case and failed to propound any discovery since his retention in February 2023. Cate also did not inform Defendant that the summary judgment motion was filed August 21, 2023, ten days afier it was served, which is the same day Defendant notified Cate that the attomey-client relationship was terminated. (Nosrat Dccl., W 5, 6.) During Catc’s representation of Defendant, Defendant was under the impression that his former counsel did in fact propound such discovery based on Cate's representations to Defendant. (Nosrat Decl., 1] 3.) Defendant attempted to bring this application last week, but his counsel did not effectuate the filing properly. (Delman Decl., 11 2.) Defendant did not become aware of the failure to propound any discovery until Cate informed Defendant about Plaintiff‘s summary judgment motion on August 21, 2023. (Nosrat Dccl., NNNNNNNNNHu—w—np—n—nm—‘p—H 1] 5.) After learning about Cate‘s failure to propound discovery, Defendant understood that he was WNOMAWN~OOWNOM#WN~O not being appropriately represented and immediately sought to retain another attorney. (Nosrat Decl., W 5-7.) Defendant wants Dana Delman to represent him, but at this time Ms. Delman is only able to appear on a limited scope basis for the purpose of seeking continuance of the summary judgment motion and serving discovery. Ms. Delman has two jury trials staning on October 27 and November 6, 2023. She does not have sufficient time to learn the case and to research and draft an opposition to the summary judgment motion as currently scheduled. (Delman Decl., 11 2.) Additionally, Ms. Delman served discovery on October 10, 2023 as she believes that she needs Plaintiff‘s responses to use as evidence in support 0f the opposition. Defendant may also need to find and retain a Swedish lawyer, as the contract at issue in this case is governed by Swedish law. The issues are complex, as Defendant believes that California law may also apply. 1 EX PARTE APPLICATION T0 CONTINUE SUMMARY JUDGMENT HEARING AND TRIAL DATES