On December 08, 2016 a
Motion-Secondary
was filed
involving a dispute between
Angelique Rochelle As Guardian Ad Litem Of,
Rochelle, Angelique,
Rochelle, Baz,
and
Deng, May,
Deng, Trevor,
Does 1 To 10,
Tan, Yu Tao,
Tan, Yu Yao,
for civil
in the District Court of San Francisco County.
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ELECTRONICALLY
FILED
Mark Hooshmand, Esq. (SBN 194878) Superior Court of California,
Tyson Redenbarger, Esq. (SBN 294424) eouey ean eandsee
Jenny Jin, Esq. (SBN 296184) 01/31/2018
7 Clerk of the Court
Hooshmand Law Group BY:EDWARD SANTOS
22 Battery Street, Ste. 610 Deputy Clerk
San Francisco, CA 94111
Tel: (415) 318-5709
Fax: (415) 376-5897
Attorneys for Plaintiff Angelique Rochelle
SUPERIOR COURT OF THE STATE OF CALIFORNIA.
COUNTY OF SAN FRANCISCO — UNLIMITED CIVIL JURISDICTION
ANGELIQUE ROCHELLE, CASE NO.: CGC-16-555761
DECLARATION OF MARK HOOSHMAND
Plaintiff, IN SUPPORT OF PLAINTIFF ANGELIQUE
ROCHELLE’S MOTION FOR A
COMPLETE, OR IN THE ALTERNATIVE,
PARTIAL JUDGMENT
NOTWITHSTANDING THE VERDICT
vs.
TREVOR DENG and DOES 1-10,
Date: — February 7, 2018
Time: 3:00 p.m.
Dept: 504
Judge: Hon. Suzanne Bolanos
Defendants.
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF ANGELIQUE
ROCHELLE’S MOTION FOR A COMPLETE, OR IN THE ALTERNATIVE, PARTIAL
JUDGMENT NOTWITHSTANDING THE VERDICT
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION FOR A
COMPLETE, OR IN THE ALTERNATIVE, PARTIAL JUDGMENT NOTWITHSTANDING THE VERDICT 1mo
So wm I DH BF Ww
ll
DECLARATION OF MARK HOOSHMAND
I, MARK HOOSHMAND, declare the following:
2.
I am the attorney of record for Plaintiff Angelique Rochelle in this matter.
The facts stated within this declaration are based upon my personal knowledge, except for
those which are based on information and belief, and I am competent to testify as to these
facts.
On January 8, 2018, my office filed and electronically served defense counsel’s office with
our Memorandum of Points and Authorities in Support of a Motion for Judgment
Notwithstanding the Verdict, and the supporting Declaration of Mark Hooshmand. My
office additionally served defense counsel personally with these motion papers.
My office did not receive a copy of Defendant’s opposition papers until it was
electronically filed and served on January 24, 2018, which is 16 calendar days after our
moving papers were filed and served.
Defense counsel’s late filing of his opposition and declaration have prejudiced us in
preparing our reply memorandum, and the Court is now afforded less time to review
Plaintiff's moving papers, before the February 7, 2018 hearing date.
In support of Plaintiff’s Motion for New Trial, declarations were submitted from two of the
jurors; Brian Glennon (Juror No. 5) and Helen Scott (Juror No. 6). These declarations both
include that, after Christopher Tirrell, the foreman, stated at the start of deliberations that a
contract supersedes the eviction and made the eviction notice moot, the jury then discussed
that it did not matter what fraud or wrongdoing Defendant committed, once a contract was
found under Question No. | of the Special Verdict Form.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Dated: January 31, 2018 Ma | p—)
Mark Hooshmand, Esq.
DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION FOR A
COMPLETE, OR IN THE ALTERNATIVE, PARTIAL JUDGMENT NOTWITHSTANDING THE VERDICT 2
Document Filed Date
January 31, 2018
Case Filing Date
December 08, 2016
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mo So wm I DH BF Ww ll ELECTRONICALLY FILED Mark Hooshmand, Esq. (SBN 194878) Superior Court of California, Tyson Redenbarger, Esq. (SBN 294424) eouey ean eandsee Jenny Jin, Esq. (SBN 296184) 01/31/2018 7 Clerk of the Court Hooshmand Law Group BY:EDWARD SANTOS 22 Battery Street, Ste. 610 Deputy Clerk San Francisco, CA 94111 Tel: (415) 318-5709 Fax: (415) 376-5897 Attorneys for Plaintiff Angelique Rochelle SUPERIOR COURT OF THE STATE OF CALIFORNIA. COUNTY OF SAN FRANCISCO — UNLIMITED CIVIL JURISDICTION ANGELIQUE ROCHELLE, CASE NO.: CGC-16-555761 DECLARATION OF MARK HOOSHMAND Plaintiff, IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION FOR A COMPLETE, OR IN THE ALTERNATIVE, PARTIAL JUDGMENT NOTWITHSTANDING THE VERDICT vs. TREVOR DENG and DOES 1-10, Date: — February 7, 2018 Time: 3:00 p.m. Dept: 504 Judge: Hon. Suzanne Bolanos Defendants. DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION FOR A COMPLETE, OR IN THE ALTERNATIVE, PARTIAL JUDGMENT NOTWITHSTANDING THE VERDICT DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION FOR A COMPLETE, OR IN THE ALTERNATIVE, PARTIAL JUDGMENT NOTWITHSTANDING THE VERDICT 1mo So wm I DH BF Ww ll DECLARATION OF MARK HOOSHMAND I, MARK HOOSHMAND, declare the following: 2. I am the attorney of record for Plaintiff Angelique Rochelle in this matter. The facts stated within this declaration are based upon my personal knowledge, except for those which are based on information and belief, and I am competent to testify as to these facts. On January 8, 2018, my office filed and electronically served defense counsel’s office with our Memorandum of Points and Authorities in Support of a Motion for Judgment Notwithstanding the Verdict, and the supporting Declaration of Mark Hooshmand. My office additionally served defense counsel personally with these motion papers. My office did not receive a copy of Defendant’s opposition papers until it was electronically filed and served on January 24, 2018, which is 16 calendar days after our moving papers were filed and served. Defense counsel’s late filing of his opposition and declaration have prejudiced us in preparing our reply memorandum, and the Court is now afforded less time to review Plaintiff's moving papers, before the February 7, 2018 hearing date. In support of Plaintiff’s Motion for New Trial, declarations were submitted from two of the jurors; Brian Glennon (Juror No. 5) and Helen Scott (Juror No. 6). These declarations both include that, after Christopher Tirrell, the foreman, stated at the start of deliberations that a contract supersedes the eviction and made the eviction notice moot, the jury then discussed that it did not matter what fraud or wrongdoing Defendant committed, once a contract was found under Question No. | of the Special Verdict Form. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: January 31, 2018 Ma | p—) Mark Hooshmand, Esq. DECLARATION OF MARK HOOSHMAND IN SUPPORT OF PLAINTIFF ANGELIQUE ROCHELLE’S MOTION FOR A COMPLETE, OR IN THE ALTERNATIVE, PARTIAL JUDGMENT NOTWITHSTANDING THE VERDICT 2