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Law Division Motion Section Initial Case Management Dates for CALENDARS (A,B,C,D,E,F,H,R,X,Z) will be heard In Person.
All otherCivil ActionInitial
Law Division Cover Sheet
Case - Case Initiation
Management Dates will be heard via Zoom (12/01/20) CCL 0520
For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12
Court Date: No hearingIN THE CIRCUIT
information was found.COURT OF COOK COUNTY, ILLINOIS FILED
COUNTY DEPARTMENT, LAW DMSION 4/17/2024 2:38 PM
IRIS Y. MARTINEZ
Justino Montiel CIRCUIT CLERK
COOK COUNTY, IL
FILED DATE: 4/17/2024 2:38 PM 2024L004201
2024L004201
Calendar, C
v. 27304748
2024L004201
Hitachi America, LTD, et al. No.
CML ACTION COVER SHEET - CASE INITIATION
A Civil Action Cover Sheet - Case Initiation shall be filed with the
complaint in all civil actions. The information contained herein
is for administrative purposes only and cannot be introduced into
evidence. Please check the box in front of the appropriate case
type which best characterizes your action. Only one (1) case type
may be checked with this cover sheet.
Jury Demand â–¡
Yes â–¡ No
PERSONAL INJURY/WRONGFUL DEATH
CASE TYPES: (FILE STAMP)
â–¡027 Motor Vehicle COMMERCIAL LITIGATION
â–¡040 Medical Malpractice
â–¡047 Asbestos
CASE TYPES:
â–¡
â–¡048 Dram Shop
002 Breach of Contract
â–¡
â–¡049 Product Liability
070 Professional Malpractice
(other than legal or medical)
â–¡051 Construction Injuries
â–¡
071 Fraud (other than legal or medical)
(including Structural Work Act, Road
â–¡
072 Consumer Fraud
â–¡
Construction Injuries Act and negligence)
â–¡
073 Breach of Warranty
â–¡
052 Railroad/PELA
053 Pediatric Lead Exposure
â–¡
074 Statutory Action
â–¡061 Other Personal Injury/Wrongful Death
â–¡
(Please specify below.**)
â–¡063 Intentional Tort
075 Other Commercial Litigation
â–¡064 Miscellaneous Statutory Action
â–¡
(Please specify below.**)
076 Retaliatory Discharge
(Please Specify Below**)
â–¡065 Premises Liability
â–¡078 Fen-phen/Redux Litigation
OTHER ACTIONS
â–¡199 Silicone Implant CASE TYPES:
â–¡ 062 Property Damage
TAX & MISCELLANEOUS REMEDIES â–¡ 066 Legal Malpractice
CASE TYPES: â–¡ 077 Libel/Slander
â–¡ 007 Confessions ofJudgment â–¡ 079 Petition for Qualified Orders
â–¡ 008 Replevin iii 084 Petition to Issue Subpoena
â–¡ 009 Tax â–¡ 100 Petition for Discovery
â–¡ 015 Condemnation **
â–¡ 017 Detinue
â–¡ 029 Unemployment Compensation
â–¡ 031 Foreign Transcript Primary Email: service@arashlaw.com
â–¡ 036 Administrative Review Action
â–¡ 085 Petition to Register ForeignJudgment Secondary Email: shana@oncalllegal.com
â–¡ 099 All Other Extraordinary Remedies
By: Arash Khorsandi, Esq., Tertiary Email: __________________
(Attorney) (Pro Se)
Pro Se Only: â–¡
I have read and agree to the terms of the Clerk's O ice Electronic Notice Policy and choose to opt in to electronic notice
form the Clerk's Office for this case at this email address: ___________________________
IRIS Y. MARTINEZ, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
Page 1 of 1
FILED
4/17/2024 2:38 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
2024L004201
Calendar, C
FILED DATE: 4/17/2024 2:38 PM 2024L004201
Subpoena in a Civil Matter (For Testimony and/or Documents) (12/01/20) CCG 0106 A
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
Justino Montiel
Plaintiff/Petitioner 2024L004201
v. Case No. CIVSB2028102
Hitachi America, LTD, et al.
Defendant/Respondent
SUBPOENA IN A CIVIL MATTER
(For Testimony and/or Documents)
To:
ISANTA
8735 W Higgins Rd Ste 300
Chicago, IL 60631-2738,
1. â–¡ YOU ARE COMMANDED to appear to give your testimony before the
Honorable ________________________________ in Room _____________ ,
_________________________________________________ , Illinois on ___________
at __________ 0 AM 0 PM
2. â–¡ YOU ARE COMMANDED to appear and give your deposition testimony before a Notary Public
at: _______________________________________________________ in Room _____________ ,
_______________________________________________ , Illinois on ___________
at __________ 0 AM 0 PM
3. YOU ARE COMMANDED to mail the following documents in your possession or control
ON-CALL LEGAL, c/o David Azema
to __________________________________ 2476 Overland Avenue, Third Fl, Los Angeles, CA 90064 ,
at ______________________________________________
8/2/24
on or before ___________ 10:00 @ AM 0 PM
at __________
(THIS IS FOR RECORDS ONLY. THERE WILL BE NO ORAL INTERROGATORIES.):
Description continued on attached page(s).
Your failure to respond to this subpoena will subject you to punishment for contempt of this Court.
Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois
cookcountyclerkofcourt.org
Page 1 of 2
Subpoena in a Civil Matter (For Testimony and/or Documents) (12/01/20) CCG 0106 B
Notice to Deponent:
1. â–¡ The deponent is a public or private corporation, partnership, association, or governmental agency. The
matter(s) on which examination is requested are as follows:
FILED DATE: 4/17/2024 2:38 PM 2024L004201
â–¡ Description continued on attached page(s).
(A nonparty organization has a duty to designate one or more officers, directors, or managing agents,
or other persons to testify on its behalf, and may set forth, for each person designated, the matters on
which that person will testify. Ill. Sup. Ct. Rule 206.)
2. □ The deponent’s testimony will be recorded by use of an audio-visual recording device, operated
by ______________________________________________ .
(Name of Recording Device Operator)
3. No discovery deposition of any party or witnesses shall exceed three hours regardless of the number of
parties involved in the case, except by stipulation of the parties or by order upon showing that good cause
warrants a lengthier examination. Ill. Sup. Ct. Rule 206(d).
@ 249405
Atty. No.: ________________
0 Pro Se 99500
Name: Arash Khorsandi, Esq. 4/17/2024 2:38 PM IRIS Y. MARTINEZ
Atty. for (if applicable): Issued by: /s/
Signature
0 Attorney Clerk of Court
Address: 2960 Wilshire Boulevard, Third Floor
Date: ___________
City: Los Angeles
CA Zip: ________
State: ____ 90010
(310) 277-7529
Telephone: ________________________
Primary Email: service@arashlaw.com
â–¡ I served this subpoena by mailing a copy, as required by Ill. Sup. Ct. Rules 11, 12 and 204(a) (2),
to ___________________ by certified mail, return receipt requested
(Receipt # ________________________) on ___________ . I paid the witness $ _____________ for
witness and mileage fees.
â–¡ I served this subpoena by handing a copy to _____________________________________________
on ___________ . I paid the witness $ _____________ for witness and mileage fees.
/s/ _________________________________________
(Signature of Server) (Print Name)
Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois
cookcountyclerkofcourt.org
Page 2 of 2
MC-025
CASE NUMBER:
SHORT TITLE:
Montiel v. Hitachi, America, LTD, et al. CIVSB2028102
ATTACHMENT (Number): _T_hr_ee_ __ __
(This Attachment may be used with any Judicial Council form.)
FILED DATE: 4/17/2024 2:38 PM 2024L004201
The following Definitions apply to each of the following Requests and shall be deemed incorporated therein.
1. "YOU" and "YOUR" shall mean the International Staple, Nail and Tool Association.
2. "KHA" shall mean and refer to Defendant KOKI HOLDINGS AMERICA, LTD., its agents, any of its
websites, its employees, its media, its social media, its investigators, and anyone or anything acting on
Defendant KHA's behalf, including but not limited to Metabo HPT.
3. "DOCUMENT" or "DOCUMENTS" means a writing, as defined in Evidence Code 250, and includes the
original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of
recording upon any tangible thing and form of communicating or representation, including letters, words,
pictures, sounds, or symbols, or combination of them.
4. "NAILER" shall mean any pneumatic nail gun.
5. "CONTACT TRIGGER" or "BUMP TRIGGER" shall mean a trigger mechanism on a NAILER that
releases (or fires) nails once both the trigger is pulled and the safety tip is pressed. The sequence of the trigger
being pulled, and safety tip being pressed, has no effect on the trigger mechanism. The mechanism does not
need to be reset; i.e., with a CONTACT TRIGGER a consumer can "bump" fire a NAILER by continuing to
pull the trigger and repeatedly pressing the safety tip.
6. "KHD" shall mean Defendant KOK.I HOLDINGS CO., LTD, a Japanese company and parent company to
KHA.
REQUESTS
1) Produce all DOCUMENTS in YOUR possession (or are obtainable by YOU with reasonable diligence)
from 1991 to present that make any mention from making any mention of claims of injuries attributed in any
way to CONTACT TRIGGERS. This request is not limited to KHA products, as it is anticipated that KHA
shall make spurious claims about industry standards a central part of its defense strategy at trial.
2) Produce all DOCUMENTS in YOUR possession (or are obtainable by YOU with reasonable diligence)
from 1991 to present that make any mention of KHA or KHD.
(If the item that this Attachment concerns is made under penalty of peljury, all statements in this Page 1 of 1
Attachment are made under penalty of peljury.) (Add pages as required)
www.courtinfo.ca gov
Form Approved for Optional Use
Judicial Council of California
ATTACHMENT
MC-025 [Rev July 1, 2009] to Judicial Council Form
FILED
4/17/2024 2:38 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
2024L004201
Calendar, C
FILED DATE: 4/17/2024 2:38 PM 2024L004201
IL Sup. Ct. Rule 204 Subpoena for a Foreign Action Cover Sheet (04/05/21) CCL 0015
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
Justino Montiel
Petitioner Illinois Case No.:
v. 2024L004201
_______________
Hitachi America, LTD, et al.
Respondent
IL SUP. CT. RULE 204 SUBPOENA FOR A FOREIGN ACTION COVER SHEET
Justino Montiel
Name: _______________________________ Name: _______________________________
N/A
Address: _____________________________ Address: _____________________________
_____________________________ _____________________________
Name: _______________________________ Name: _______________________________
Address: _____________________________ Address: _____________________________
____________________________ _____________________________
Name: _______________________________ Name: _______________________________
Address: _____________________________ Address: _____________________________
_____________________________ _____________________________
249405
Atty. No.: ________________ Pro Se 99500
Atty Name: Arash Khorsandi, Esq.,
Atty. for: plaintiff, Justino Montiel
Address: 2960 Wilshire Boulevard
Los Angeles
City: ____________________________ CA
State: ____ 90010
Zip: ________
(310) 277-7529
Telephone: ________________________
Primary Email: service@arashlaw.com
Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois
cookcountyclerkofcourt.org
Page 1 of 1
Preview
Law Division Motion Section Initial Case Management Dates for CALENDARS (A,B,C,D,E,F,H,R,X,Z) will be heard In Person. All otherCivil ActionInitial Law Division Cover Sheet Case - Case Initiation Management Dates will be heard via Zoom (12/01/20) CCL 0520 For more information and Zoom Meeting IDs go to https.//www.cookcountycourt,org/HOME?Zoom-Links?Agg4906_SelectTab/12 Court Date: No hearingIN THE CIRCUIT information was found.COURT OF COOK COUNTY, ILLINOIS FILED COUNTY DEPARTMENT, LAW DMSION 4/17/2024 2:38 PM IRIS Y. MARTINEZ Justino Montiel CIRCUIT CLERK COOK COUNTY, IL FILED DATE: 4/17/2024 2:38 PM 2024L004201 2024L004201 Calendar, C v. 27304748 2024L004201 Hitachi America, LTD, et al. No. CML ACTION COVER SHEET - CASE INITIATION A Civil Action Cover Sheet - Case Initiation shall be filed with the complaint in all civil actions. The information contained herein is for administrative purposes only and cannot be introduced into evidence. Please check the box in front of the appropriate case type which best characterizes your action. Only one (1) case type may be checked with this cover sheet. Jury Demand □ Yes □ No PERSONAL INJURY/WRONGFUL DEATH CASE TYPES: (FILE STAMP) □027 Motor Vehicle COMMERCIAL LITIGATION □040 Medical Malpractice □047 Asbestos CASE TYPES: □ □048 Dram Shop 002 Breach of Contract □ □049 Product Liability 070 Professional Malpractice (other than legal or medical) □051 Construction Injuries □ 071 Fraud (other than legal or medical) (including Structural Work Act, Road □ 072 Consumer Fraud □ Construction Injuries Act and negligence) □ 073 Breach of Warranty □ 052 Railroad/PELA 053 Pediatric Lead Exposure □ 074 Statutory Action □061 Other Personal Injury/Wrongful Death □ (Please specify below.**) □063 Intentional Tort 075 Other Commercial Litigation □064 Miscellaneous Statutory Action □ (Please specify below.**) 076 Retaliatory Discharge (Please Specify Below**) □065 Premises Liability □078 Fen-phen/Redux Litigation OTHER ACTIONS □199 Silicone Implant CASE TYPES: □ 062 Property Damage TAX & MISCELLANEOUS REMEDIES □ 066 Legal Malpractice CASE TYPES: □ 077 Libel/Slander □ 007 Confessions ofJudgment □ 079 Petition for Qualified Orders □ 008 Replevin iii 084 Petition to Issue Subpoena □ 009 Tax □ 100 Petition for Discovery □ 015 Condemnation ** □ 017 Detinue □ 029 Unemployment Compensation □ 031 Foreign Transcript Primary Email: service@arashlaw.com □ 036 Administrative Review Action □ 085 Petition to Register ForeignJudgment Secondary Email: shana@oncalllegal.com □ 099 All Other Extraordinary Remedies By: Arash Khorsandi, Esq., Tertiary Email: __________________ (Attorney) (Pro Se) Pro Se Only: □ I have read and agree to the terms of the Clerk's O ice Electronic Notice Policy and choose to opt in to electronic notice form the Clerk's Office for this case at this email address: ___________________________ IRIS Y. MARTINEZ, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Page 1 of 1 FILED 4/17/2024 2:38 PM IRIS Y. MARTINEZ CIRCUIT CLERK COOK COUNTY, IL 2024L004201 Calendar, C FILED DATE: 4/17/2024 2:38 PM 2024L004201 Subpoena in a Civil Matter (For Testimony and/or Documents) (12/01/20) CCG 0106 A IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS Justino Montiel Plaintiff/Petitioner 2024L004201 v. Case No. CIVSB2028102 Hitachi America, LTD, et al. Defendant/Respondent SUBPOENA IN A CIVIL MATTER (For Testimony and/or Documents) To: ISANTA 8735 W Higgins Rd Ste 300 Chicago, IL 60631-2738, 1. □ YOU ARE COMMANDED to appear to give your testimony before the Honorable ________________________________ in Room _____________ , _________________________________________________ , Illinois on ___________ at __________ 0 AM 0 PM 2. □ YOU ARE COMMANDED to appear and give your deposition testimony before a Notary Public at: _______________________________________________________ in Room _____________ , _______________________________________________ , Illinois on ___________ at __________ 0 AM 0 PM 3. YOU ARE COMMANDED to mail the following documents in your possession or control ON-CALL LEGAL, c/o David Azema to __________________________________ 2476 Overland Avenue, Third Fl, Los Angeles, CA 90064 , at ______________________________________________ 8/2/24 on or before ___________ 10:00 @ AM 0 PM at __________ (THIS IS FOR RECORDS ONLY. THERE WILL BE NO ORAL INTERROGATORIES.): Description continued on attached page(s). Your failure to respond to this subpoena will subject you to punishment for contempt of this Court. Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois cookcountyclerkofcourt.org Page 1 of 2 Subpoena in a Civil Matter (For Testimony and/or Documents) (12/01/20) CCG 0106 B Notice to Deponent: 1. □ The deponent is a public or private corporation, partnership, association, or governmental agency. The matter(s) on which examination is requested are as follows: FILED DATE: 4/17/2024 2:38 PM 2024L004201 □ Description continued on attached page(s). (A nonparty organization has a duty to designate one or more officers, directors, or managing agents, or other persons to testify on its behalf, and may set forth, for each person designated, the matters on which that person will testify. Ill. Sup. Ct. Rule 206.) 2. □ The deponent’s testimony will be recorded by use of an audio-visual recording device, operated by ______________________________________________ . (Name of Recording Device Operator) 3. No discovery deposition of any party or witnesses shall exceed three hours regardless of the number of parties involved in the case, except by stipulation of the parties or by order upon showing that good cause warrants a lengthier examination. Ill. Sup. Ct. Rule 206(d). @ 249405 Atty. No.: ________________ 0 Pro Se 99500 Name: Arash Khorsandi, Esq. 4/17/2024 2:38 PM IRIS Y. MARTINEZ Atty. for (if applicable): Issued by: /s/ Signature 0 Attorney Clerk of Court Address: 2960 Wilshire Boulevard, Third Floor Date: ___________ City: Los Angeles CA Zip: ________ State: ____ 90010 (310) 277-7529 Telephone: ________________________ Primary Email: service@arashlaw.com □ I served this subpoena by mailing a copy, as required by Ill. Sup. Ct. Rules 11, 12 and 204(a) (2), to ___________________ by certified mail, return receipt requested (Receipt # ________________________) on ___________ . I paid the witness $ _____________ for witness and mileage fees. □ I served this subpoena by handing a copy to _____________________________________________ on ___________ . I paid the witness $ _____________ for witness and mileage fees. /s/ _________________________________________ (Signature of Server) (Print Name) Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois cookcountyclerkofcourt.org Page 2 of 2 MC-025 CASE NUMBER: SHORT TITLE: Montiel v. Hitachi, America, LTD, et al. CIVSB2028102 ATTACHMENT (Number): _T_hr_ee_ __ __ (This Attachment may be used with any Judicial Council form.) FILED DATE: 4/17/2024 2:38 PM 2024L004201 The following Definitions apply to each of the following Requests and shall be deemed incorporated therein. 1. "YOU" and "YOUR" shall mean the International Staple, Nail and Tool Association. 2. "KHA" shall mean and refer to Defendant KOKI HOLDINGS AMERICA, LTD., its agents, any of its websites, its employees, its media, its social media, its investigators, and anyone or anything acting on Defendant KHA's behalf, including but not limited to Metabo HPT. 3. "DOCUMENT" or "DOCUMENTS" means a writing, as defined in Evidence Code 250, and includes the original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combination of them. 4. "NAILER" shall mean any pneumatic nail gun. 5. "CONTACT TRIGGER" or "BUMP TRIGGER" shall mean a trigger mechanism on a NAILER that releases (or fires) nails once both the trigger is pulled and the safety tip is pressed. The sequence of the trigger being pulled, and safety tip being pressed, has no effect on the trigger mechanism. The mechanism does not need to be reset; i.e., with a CONTACT TRIGGER a consumer can "bump" fire a NAILER by continuing to pull the trigger and repeatedly pressing the safety tip. 6. "KHD" shall mean Defendant KOK.I HOLDINGS CO., LTD, a Japanese company and parent company to KHA. REQUESTS 1) Produce all DOCUMENTS in YOUR possession (or are obtainable by YOU with reasonable diligence) from 1991 to present that make any mention from making any mention of claims of injuries attributed in any way to CONTACT TRIGGERS. This request is not limited to KHA products, as it is anticipated that KHA shall make spurious claims about industry standards a central part of its defense strategy at trial. 2) Produce all DOCUMENTS in YOUR possession (or are obtainable by YOU with reasonable diligence) from 1991 to present that make any mention of KHA or KHD. (If the item that this Attachment concerns is made under penalty of peljury, all statements in this Page 1 of 1 Attachment are made under penalty of peljury.) (Add pages as required) www.courtinfo.ca gov Form Approved for Optional Use Judicial Council of California ATTACHMENT MC-025 [Rev July 1, 2009] to Judicial Council Form FILED 4/17/2024 2:38 PM IRIS Y. MARTINEZ CIRCUIT CLERK COOK COUNTY, IL 2024L004201 Calendar, C FILED DATE: 4/17/2024 2:38 PM 2024L004201 IL Sup. Ct. Rule 204 Subpoena for a Foreign Action Cover Sheet (04/05/21) CCL 0015 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION Justino Montiel Petitioner Illinois Case No.: v. 2024L004201 _______________ Hitachi America, LTD, et al. Respondent IL SUP. CT. RULE 204 SUBPOENA FOR A FOREIGN ACTION COVER SHEET Justino Montiel Name: _______________________________ Name: _______________________________ N/A Address: _____________________________ Address: _____________________________ _____________________________ _____________________________ Name: _______________________________ Name: _______________________________ Address: _____________________________ Address: _____________________________ ____________________________ _____________________________ Name: _______________________________ Name: _______________________________ Address: _____________________________ Address: _____________________________ _____________________________ _____________________________ 249405 Atty. No.: ________________ Pro Se 99500 Atty Name: Arash Khorsandi, Esq., Atty. for: plaintiff, Justino Montiel Address: 2960 Wilshire Boulevard Los Angeles City: ____________________________ CA State: ____ 90010 Zip: ________ (310) 277-7529 Telephone: ________________________ Primary Email: service@arashlaw.com Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois cookcountyclerkofcourt.org Page 1 of 1