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ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
FERRIS K7 BRITTON SAN BERNARDINO DISTRICT
A Professional Corporation 12/1/2023 7:58 AM
Scott H. Toothacre(SBN 146530)
Elyssa K. Kulas (SBN 3 17559) By: Gloria Portillo, DEPUTY
Michael R. Weinstein (SBN 106464)
501 West Broadway, Suite 1450
San Diego, California 92 1 01
©OOQONUl-bUJNr—A
Telephone: (6 1 9) 233-3 1 31
Fax: (619) 232-9316
stoothacre@ferrisbritton.com
ekulas@ferrisbritton.com
mweinstein@ferrisbritton.com
Attorneys for Plaintiffs
ARSEN H. VARTANIAN and,
AV AUTOMOTIVE, INC., and
Cross—Defendant and Cross-Complainant
EDGAR PORTILLO
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO-RANCHO CUCAMONGA DISTRICT
ARSEN H. VARTANIAN, an individual; AV Case No. CIVSB2210697
AUTOMOTIVE, INC., a California Corporation,
Judge: Hon. Janet M. Frangie
Plaintiffs, Dept: R1
V. CROSS-DEFENDANT, EDGAR
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PORTILLO’S CROSS-COMPLAINT
VAHAK VARTANIAN, an individual, doing AGAINST VAHAK VARTANIAN
business as Vartanian 0n Wheels and VOW
AUTOMOTIVE; and DOES 1 through 35, Jury Trial Demanded
inclusive,
OONONLh-waHO©OOflO\Lh-5UJNHO
Defendants.
VAHAK VARTANIAN, an individual,
Cross—Complainant.
V.
ARSEN H. VARTANIAN, an individual; EDGAR
PORTILLO, an individual, and ROES 1 to 20,
inclusive,
Action Filed: June 9, 2022
Cross-Defendants. Trial Date: Not Yet Set
1
CROSS-DEFENDANT, EDGAR PORTILLO’S CROSS-COMPLAINT AGAINST VAHAK VARTANIAN DBA
VARTANIAN ON WHEELS AND VOW AUTOMOTIVE
EDGAR PORTILLO, an individual,
Cross-Complainant,
V.
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VAHAK VARTANIAN, an individual, doing
business as Vartanian 0n Wheels and VOW
AUTOMOTIVE; and ZOES 25 through 35,
inclusive,
Cross-Defendants.
Pursuant t0 CCP §§ 426.30(a), 426.10(c), 428.10, 428.50, Cross—Complainant Edgar Portillo files
this Cross—Complaint against Cross-Defendants, Vahak Vartanian, an individual, doing business as
Vartanian 0n Wheels and VOW Automotive, and ZOES 25 through 35, inclusive, and allege, as follows:
JURISDICTION & VENUE
1. This Court has general jurisdiction over this action and over all defendants under
California Code of Civil Procedure § 410.10. Cross-Complainant Edgar Portillo seeks money damages
from Cross—Defendant Vahak Vartanian in excess 0f the jurisdictional minimum, according to proof at
trial.
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2. Venue is proper under California Code of Civil Procedure §§ 395 and 395.5, because
defendant Vahak Vartanian resides in and a substantial portion of the events forming the basis of this
OONONLh-waHO©OOflO\Lh-5UJNHO
action occurred in the County 0f San Bernardino, State 0f California.
PARTIES
3. Plaintiff and Cross—Defendant, ARSEN VARTANIAN (hereinafter “Arsen”1), was born
and raised in Lebanon and immigrated to the United States in approximately 1984. Arsen’s primary
language is Armenian and his speaking, reading and writing skills in English are poor, at best. Arsen is
a resident of the City of Jurupa Valley, County 0f Riverside, California.
4. Arsen is currently 73 years 01d. At all times relevant herein, Arsen was older than 65
years of age, and thus an “elder” under Welfare & Institutions Code §15610.27, and a senior citizen as
1
Because two 0f the parties share the same last name, we Will refer t0 the individual parties throughout this Cross-
Complaint by their first names only.
2
CROSS-DEFENDANT, EDGAR PORTILLO’S CROSS-COMPLAINT AGAINST VAHAK VARTANIAN DBA
VARTANIAN ON WHEELS AND VOW AUTOMOTIVE
Preview
ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO FERRIS K7 BRITTON SAN BERNARDINO DISTRICT A Professional Corporation 12/1/2023 7:58 AM Scott H. Toothacre(SBN 146530) Elyssa K. Kulas (SBN 3 17559) By: Gloria Portillo, DEPUTY Michael R. Weinstein (SBN 106464) 501 West Broadway, Suite 1450 San Diego, California 92 1 01 ©OOQONUl-bUJNr—A Telephone: (6 1 9) 233-3 1 31 Fax: (619) 232-9316 stoothacre@ferrisbritton.com ekulas@ferrisbritton.com mweinstein@ferrisbritton.com Attorneys for Plaintiffs ARSEN H. VARTANIAN and, AV AUTOMOTIVE, INC., and Cross—Defendant and Cross-Complainant EDGAR PORTILLO SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO-RANCHO CUCAMONGA DISTRICT ARSEN H. VARTANIAN, an individual; AV Case No. CIVSB2210697 AUTOMOTIVE, INC., a California Corporation, Judge: Hon. Janet M. Frangie Plaintiffs, Dept: R1 V. CROSS-DEFENDANT, EDGAR NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—K PORTILLO’S CROSS-COMPLAINT VAHAK VARTANIAN, an individual, doing AGAINST VAHAK VARTANIAN business as Vartanian 0n Wheels and VOW AUTOMOTIVE; and DOES 1 through 35, Jury Trial Demanded inclusive, OONONLh-waHO©OOflO\Lh-5UJNHO Defendants. VAHAK VARTANIAN, an individual, Cross—Complainant. V. ARSEN H. VARTANIAN, an individual; EDGAR PORTILLO, an individual, and ROES 1 to 20, inclusive, Action Filed: June 9, 2022 Cross-Defendants. Trial Date: Not Yet Set 1 CROSS-DEFENDANT, EDGAR PORTILLO’S CROSS-COMPLAINT AGAINST VAHAK VARTANIAN DBA VARTANIAN ON WHEELS AND VOW AUTOMOTIVE EDGAR PORTILLO, an individual, Cross-Complainant, V. ©OOQONUl-bUJNr—A VAHAK VARTANIAN, an individual, doing business as Vartanian 0n Wheels and VOW AUTOMOTIVE; and ZOES 25 through 35, inclusive, Cross-Defendants. Pursuant t0 CCP §§ 426.30(a), 426.10(c), 428.10, 428.50, Cross—Complainant Edgar Portillo files this Cross—Complaint against Cross-Defendants, Vahak Vartanian, an individual, doing business as Vartanian 0n Wheels and VOW Automotive, and ZOES 25 through 35, inclusive, and allege, as follows: JURISDICTION & VENUE 1. This Court has general jurisdiction over this action and over all defendants under California Code of Civil Procedure § 410.10. Cross-Complainant Edgar Portillo seeks money damages from Cross—Defendant Vahak Vartanian in excess 0f the jurisdictional minimum, according to proof at trial. NNNNNNNNNr—tr—tr—tr—tr—tr—tr—tr—tr—tr—K 2. Venue is proper under California Code of Civil Procedure §§ 395 and 395.5, because defendant Vahak Vartanian resides in and a substantial portion of the events forming the basis of this OONONLh-waHO©OOflO\Lh-5UJNHO action occurred in the County 0f San Bernardino, State 0f California. PARTIES 3. Plaintiff and Cross—Defendant, ARSEN VARTANIAN (hereinafter “Arsen”1), was born and raised in Lebanon and immigrated to the United States in approximately 1984. Arsen’s primary language is Armenian and his speaking, reading and writing skills in English are poor, at best. Arsen is a resident of the City of Jurupa Valley, County 0f Riverside, California. 4. Arsen is currently 73 years 01d. At all times relevant herein, Arsen was older than 65 years of age, and thus an “elder” under Welfare & Institutions Code §15610.27, and a senior citizen as 1 Because two 0f the parties share the same last name, we Will refer t0 the individual parties throughout this Cross- Complaint by their first names only. 2 CROSS-DEFENDANT, EDGAR PORTILLO’S CROSS-COMPLAINT AGAINST VAHAK VARTANIAN DBA VARTANIAN ON WHEELS AND VOW AUTOMOTIVE