On August 15, 2018 a
Request,Application
was filed
involving a dispute between
Grossman, Marc,
and
Does 1-10,
Tesla, Inc,
for Business Tort/Unfair Business Practice Unlimited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
Soheyl Tahsildoost (Bar No. 271294) ggfiigleglgggfigggNgARLgfigNIA
Nathaniel R. Cowden (Bar No. 3 14983)
THETA LAW FIRM, LLP SAN BERNARDINO DISTRICT
12100 Wilshire B1Vd., Ste 1070 11/22/2023 7:45 pM
Los Angeles, CA 90025
Telephone: (424) 297-3103 By: Aradelsi Rizo, DEPUTY
Facsimile: (424) 286-2244
Attorneys for Defendant, TESLA, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
MARC GROSSMAN, an individual, Case N0.: CIVDS 1 82 1 328
10
Plaintiff, DEFENDANT TESLA’S REQUEST FOR
11 JUDICIAL NOTICE IN SUPPORT OF
VS. DEFENDANT’S MOTION FOR SUMMARY
12 JUDGMENT/ADJUDICATION
TESLA, INC. WHICH WILL DO
13 BUSINESS AS TESLA MOTORS, INC.; [Submitted concurrently with Notice of
and DOES 1-10, Motion and Motion for Summary
14 Judgment/Adjudication; Memorandum of
Defendant. Points and Authorities in Support 0f
15 Defendant’s Motion; Separate Statement 0f
Undisputed Material Facts; Declaration 0f
16 vvvvvvvvvvvvvvvvvvvvvvvvvvv
Soheyl Tahsildoost and exhibits thereto;
Declaration of Raymond Kim and exhibits
17 thereto; and [Proposed] Order]
18 Dept: $25
Judge: Hon. Khymberli S. Apaloo
19
Date: February 28, 2024
20 Time: 8:30 A.M.
21 Complaint Filed: August 15, 2018
Trial Date: March 11, 2024
22
23
TO ALL PARTIES AND THEIR ATTORNEY’S OF RECORD:
24
PLEASE TAKE NOTICE THAT, Defendant Tesla, Inc. (“Tesla”) requests that this Court
25
take judicial notice of the following pursuant t0 California Evidence Code section 452 and 453 in
26
connection With Tesla’s motion for summary judgment/adjudication:
27
1. Plaintiff s Complaint against Defendant Tesla Inc., Case No. CIVDS 1 821328,
28
filed on in the San Bernardino County Superior Court. Tesla also requests that this Court take
1
DEFENDANT TESLA INC.’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT/ADJUDICATION
judicial notice 0f the filing date as August 15, 2018. (Exhibit 4 to Tahsildoost Decl.)
2. Tesla’s Answer to Plaintiff’s Complaint, Case N0. Case No. CIVDS 1 821328,
filed 0n September 28, 2018 in the San Bernardino County Superior Court. Specifically, Tesla
requests that this Court take judicial notice of all of Tesla’s Affirmative Defenses. (Exhibit 5 to
Tahsildoost Decl.)
3. Tesla’s Proposed C.C.P. 998 offer. Specifically, Tesla requests that this Court
take judicial notice of the amount of the offer Which as set therein is $7,500.00. (Exhibit 6 to
Tahsildoost Decl.)
4. Search results of Plaintiff Marc Grossman in the San Bernardino Superior Court’s
10 Case Information and Document Sales online portal. (Exhibit 13 to Tahsildoost Decl.)
11 5. The State Bar of California Attorney Licensee Profile of Plaintiff Marc E.
12 Grossman, Bar Number 197627. Specifically, Tesla requests that this Court take judicial notice
13 November 24, 1998, the date that Plaintiff was admitted t0 the California bar and started
14 practicing law. (Exhibit 11 to Tahsildoost Decl.)
15 6. Plaintiff’ s First Amended Complaint against Defendant Tesla Inc., Case No.
16 CIVD81821328, filed on in the San Bernardino County Superior Court. Tesla also requests that
17 this Court take judicial notice of the filing date as September 4, 2020. (Exhibit 19 to Tahsildoost
18 Decl.)
19 7. Plaintiff s Second Amended Complaint against Defendant Tesla Inc., Case No.
20 CIVD81821328, filed on in the San Bernardino County Superior Court. Tesla also requests that
21 this Court take judicial notice of the filing date as December 14, 2020. (Exhibit 15 to Tahsildoost
22 Decl.)
23 8. Plaintiff s Third Amended Complaint against Defendant Tesla Inc., Case N0.
24 CIVDSI821328, filed 0n in the San Bernardino County Superior Court. Tesla also requests that
25 this Court take judicial notice 0f the filing date as September 16, 2021. (Exhibit 16 t0
26 Tahsildoost Decl.)
27 9. Tesla’s Answer to Plaintiff’ s Third Amended Complaint, Case No. Case No.
28 CIVD81821328, filed on June 15, 2022 in the San Bernardino County Superior Court.
2
DEFENDANT TESLA INC.’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT/ADJUDICATION
Document Filed Date
November 22, 2023
Case Filing Date
August 15, 2018
Category
Business Tort/Unfair Business Practice Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
ELECTRONICALLY FILED Soheyl Tahsildoost (Bar No. 271294) ggfiigleglgggfigggNgARLgfigNIA Nathaniel R. Cowden (Bar No. 3 14983) THETA LAW FIRM, LLP SAN BERNARDINO DISTRICT 12100 Wilshire B1Vd., Ste 1070 11/22/2023 7:45 pM Los Angeles, CA 90025 Telephone: (424) 297-3103 By: Aradelsi Rizo, DEPUTY Facsimile: (424) 286-2244 Attorneys for Defendant, TESLA, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO MARC GROSSMAN, an individual, Case N0.: CIVDS 1 82 1 328 10 Plaintiff, DEFENDANT TESLA’S REQUEST FOR 11 JUDICIAL NOTICE IN SUPPORT OF VS. DEFENDANT’S MOTION FOR SUMMARY 12 JUDGMENT/ADJUDICATION TESLA, INC. WHICH WILL DO 13 BUSINESS AS TESLA MOTORS, INC.; [Submitted concurrently with Notice of and DOES 1-10, Motion and Motion for Summary 14 Judgment/Adjudication; Memorandum of Defendant. Points and Authorities in Support 0f 15 Defendant’s Motion; Separate Statement 0f Undisputed Material Facts; Declaration 0f 16 vvvvvvvvvvvvvvvvvvvvvvvvvvv Soheyl Tahsildoost and exhibits thereto; Declaration of Raymond Kim and exhibits 17 thereto; and [Proposed] Order] 18 Dept: $25 Judge: Hon. Khymberli S. Apaloo 19 Date: February 28, 2024 20 Time: 8:30 A.M. 21 Complaint Filed: August 15, 2018 Trial Date: March 11, 2024 22 23 TO ALL PARTIES AND THEIR ATTORNEY’S OF RECORD: 24 PLEASE TAKE NOTICE THAT, Defendant Tesla, Inc. (“Tesla”) requests that this Court 25 take judicial notice of the following pursuant t0 California Evidence Code section 452 and 453 in 26 connection With Tesla’s motion for summary judgment/adjudication: 27 1. Plaintiff s Complaint against Defendant Tesla Inc., Case No. CIVDS 1 821328, 28 filed on in the San Bernardino County Superior Court. Tesla also requests that this Court take 1 DEFENDANT TESLA INC.’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY JUDGMENT/ADJUDICATION judicial notice 0f the filing date as August 15, 2018. (Exhibit 4 to Tahsildoost Decl.) 2. Tesla’s Answer to Plaintiff’s Complaint, Case N0. Case No. CIVDS 1 821328, filed 0n September 28, 2018 in the San Bernardino County Superior Court. Specifically, Tesla requests that this Court take judicial notice of all of Tesla’s Affirmative Defenses. (Exhibit 5 to Tahsildoost Decl.) 3. Tesla’s Proposed C.C.P. 998 offer. Specifically, Tesla requests that this Court take judicial notice of the amount of the offer Which as set therein is $7,500.00. (Exhibit 6 to Tahsildoost Decl.) 4. Search results of Plaintiff Marc Grossman in the San Bernardino Superior Court’s 10 Case Information and Document Sales online portal. (Exhibit 13 to Tahsildoost Decl.) 11 5. The State Bar of California Attorney Licensee Profile of Plaintiff Marc E. 12 Grossman, Bar Number 197627. Specifically, Tesla requests that this Court take judicial notice 13 November 24, 1998, the date that Plaintiff was admitted t0 the California bar and started 14 practicing law. (Exhibit 11 to Tahsildoost Decl.) 15 6. Plaintiff’ s First Amended Complaint against Defendant Tesla Inc., Case No. 16 CIVD81821328, filed on in the San Bernardino County Superior Court. Tesla also requests that 17 this Court take judicial notice of the filing date as September 4, 2020. (Exhibit 19 to Tahsildoost 18 Decl.) 19 7. Plaintiff s Second Amended Complaint against Defendant Tesla Inc., Case No. 20 CIVD81821328, filed on in the San Bernardino County Superior Court. Tesla also requests that 21 this Court take judicial notice of the filing date as December 14, 2020. (Exhibit 15 to Tahsildoost 22 Decl.) 23 8. Plaintiff s Third Amended Complaint against Defendant Tesla Inc., Case N0. 24 CIVDSI821328, filed 0n in the San Bernardino County Superior Court. Tesla also requests that 25 this Court take judicial notice 0f the filing date as September 16, 2021. (Exhibit 16 t0 26 Tahsildoost Decl.) 27 9. Tesla’s Answer to Plaintiff’ s Third Amended Complaint, Case No. Case No. 28 CIVD81821328, filed on June 15, 2022 in the San Bernardino County Superior Court. 2 DEFENDANT TESLA INC.’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY JUDGMENT/ADJUDICATION