Motion in Limine Evidentiary in ANDY SABERI VS LES STANFORD, ETAL| Trellis.Law

On November 18, 2015 a Motion-Secondary was filed involving a dispute between Les Stanford Chevrolet Cadillac, Inc, Saberi, Andy, and Bj Interstate Autotransporters, Inc, Dedyk, Bogdan, Les Stanford Chevrolet Cadillac, Inc, for (06) Unlimited Breach of Contract/Warranty in the District Court of San Mateo County.

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JAMESM. DOMBROSKI, ESQ. (SBN 56898)
LAW OFFICE OF JAMES M. DOMBROSKI FILED
Post Office Box 751027 SAN MATEO COUNTY
Petaluma, CA 94975 OCT - 5 2018
Tel: (707) 762-7807
Fax: (707) 769-0419 Glerk of Court
MAL,
THOMASI. SABERI, ESQ. (SBN 169652)
1045 Airport Blvd., Suite 12
So. San Francisco, CA 94080
Telephone: (650) 588-2428
Facsimile: (650) 873-7046

Attorneys for Plaintiff

10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
IN AND FOR THE COUNTY OF SAN MATEO
12
13
ANDY SABERI, CASE NO. CIV 536294
14
Plaintiff, Complaint filed: 11/18/2015
15
VS. DECLARATION OF JAMES M.
16 DOMBROSKI IN SUPPORT OF
LES STANFORD CHEVROLET CADILLAC PLAINTIFF’S OPPOSITION TO
17 INC., etc., et al
DEFENDANT, BJ INTERSTATE AUTO
18 Defendants. TRANSPORTERS, INC.’S MOTION IN
LIMINE RE LACK OF INSURANCE;
19 DECLARATION OF JAMES M.
ae ~ DOMBROSKI; PROOF OF SERVICE
20 i \
|
21 Deaton in Support DATE: October 15, 2018
TIME: 9:00 a.m.
BY FAY

| il l ll mn
22
| JUDGE: Presiding Judge Susan Irene Etezadi
l DEPT: 18, Courtroom 2
23 /}

24 I, JamesM. Dombroski, declare’
25 1 I am an attorney at law licensed to practice in the State of California, and am the
26 attorney of record for Plaintiff in the above-entitled action
27 2 The matters contained in this declaration are known to me personally, and if
28 called upon to testify as to such matters under oath in a court of Jaw, I could and would do so
1
DECLARATION OF JAMES M. DOMBROSKI IN SUPPORT OF PLAINTIFF’S OPPOSITION
TO DEFENDANT’S MOTION IN LIMINE RE LACK OF INSURANCE
competently.
3 One of the contentions raised in the Complaint in this action is that BJ Interstate
Auto Transporters, Inc. (hereinafter “BJ”), was negligent in brokering the transportation of my
client’s automobile to an uninsured carrier, although this was not the exclusive basis for the

claim of negligence against BJ. A copy of the Complaint is attached hereto and incorporated
herein by reference as Exhibit “1” as though fully set forth hereat. (See Fourth Cause of Action)
4 A deposition of Bogdan Dedyk was taken in this action on March 9, 2018. BJ’s
counsel asserts that Mr. Dedyk stated at page 76, lines 23-25 of said deposition transcript, that
his company was insured. It is not clear to me how counsel for BJ obtained this page of the
10 deposition transcript, but the page has been altered, is incorrect, and is NOT. THE ACTUAL

11 PAGE from the deposition transcript. An excerpt of said deposition transcript, i.e., specifically
12 page 76, is attached hereto and incorporated herein by reference as Exhibit “2” as though fully

13 set forth hereat. The actual page of the deposition transcript states that Mr. Dedyk testified his

14 company did NOT have insurance. The court reporter who has confirmed that there were no

15 changes to the deposition transcript. A copy of the letter form the court reporter regarding lack

16 of any changes is attached hereto and incorporated herein by reference as Exhibit “3” as though

17 fully set forth hereat. I am also attaching a copy of the verification from the court reporter,

18 copy of which is attached hereto and incorporated herein by reference as Exhibit “4” as though

19 fully set forth hereat.

20 5 To the extent a fact has been admitted by my client, the consequences of such

21 admission should be applied at the time of trial. However, there was no necessity for defendant’s

22 motion in limine on this point.

23 I declare under penalty of perjury that the foregoing is true and correct and that this

24 declaration was executed on October 4 > 2018 Juma, California.

26 J E M. DOMBROSKI
27
28
2

DECLARATION OF JAMES M. DOMBROSKI IN SUPPORT OF PLAINTIFF’S OPPOSITION
TO DEFENDANT’S MOTION IN LIMINE RE LACK OF INSURANCE

wee

JAMES M. DOMBROSKI (SBN 56898)
LAW OFFICE OF JAMES M. DOMBROSKI
Post Office Box 751027
Petaluma, CA. 94975
Tel. (707) 762-7807
Fax. (707) 769-0419

THOMAS |. SABERI, ESQ. (SBN 536294)
LAW OFFICE OF WILLIAM H. PAYNTER
1045 Airport Blvd., Suite 12
So. San Francisco, CA 94080
Telephone: (650) 588-2428
Facsimile: (650) 873-7046

Attorneys for Plaintiff ANDY SABERI.
10

11 SUPERIOR COURT OF THE STATE OF CALIF ORNIA

12 IN AND FOR THE COUNTY OF SAN MATEO
13 UNLIMITED JURISDICTION
14
ANDY SABERI, an individual, CASE NO. 536294
15
Plaintiff, FIRST AMENDED COMPLAINT FOR
16
vs.
DAMAGES
(Jury Trial Demanded)
17
LES STANFORD CHEVROLET CADILLAC,
18 INC., a Michigan corporation, BJ INTERSTATE,
AUTO TRANSPORTERS, INC., a Nevada
19
corporation, BOGDAN DEDYK, doing )
business as SAFE AUTO TRANSPORT, an
)
20
individual, and DOES | through 25, inclusive, )
21
Defendants. )
22

23 Plaintiff, Andy Saberi, alleges in his First Amended Complaint as follows:

24 I
25 PARTIES
26 1 Plaintiff Andy Saberi (hereinafter “Saberi”) is an individual located in San Mateo
27 County. California.
28 22. Defendant Les Stanford Chevrolet Cadillac, Inc. (hereinafter “Les Stanford”), at all

1
First Amended Complaint
for Damages

oe ~ -Exhibit |
times herein mentioned, is located at 21730 Michigan Avenue, Dearborn, Michigan 48124. Upon

information and belief, Les Stanford is a corporation duly organized and existing under the laws
of the State of Michigan.

3 Defendant BJ Interstate Auto Transporters, Inc. (hereinafter “BJ Interstate”), at all

times herein mentioned, is located at 6625 W, Sahara Avenue, Suite 1, Las Vegas, Nevada 89146.

Upon information and belief, BJ Interstate is a corporation duly organized and existing under the
laws of the State of Nevada.
4 Defendant Bogdan Dedyk, doing business as Safe Auto Transport (hereinafter

“Safe Auto”), at all times herein mentioned, upon information and belief, is an individual whose

10 address is 1756 Heather Garden Lane, Roseville, California 95661.
<
it > The true names and capacities of DOES I through 25, inclusive, are unknown to
12 Plaintiff. Plaintiff will amend this Complaint to set forth the true names and capacities of the

13 DOE Defendants (as soon as the same have been ascertained).

14 6 At all relevant times, each of the Defendants have been the agent, employee, or

15 co-conspirator with the remaining Defendants, and each was acting within the course and scope
16 of such agency, employment or conspiracy.

17 tL.

18 FACTUAL ALLEGATIONS
7
19 On or about September 17, 2015, Saberi entered into a Vehicle Purchase Order

20 with Les Stanford for the purchase of a “new” 2016 Chevrolet Corvette Z06 convertible

21 (hereinafter “Corvette”) for the sum of $128,391.93, attached as Exhibit A. Before Saberi
22 purchased the Corvette from Les Stanford, Les Stanford, through its agents and employees,

expressly and impliedly warranted and represented that the Corvette was “new” and free from

24 defects and in all respects safe for use in the manner for which it was designated and
25 manufactured and expressly and impliedly warranted that the Corvette was of merchantable
26 qualify and fit for the purpose intended. Saberi relied on these warranties and representations in

27 purchasing the Corvette and made full payment in the sum of $128,391.93.

28 8. Upon information and belief, Defendant Les Stanford is the representative of the

2
First Amended Complaintfor Damages

a — a
manufacturer of the Corvette purchased by Saberi, which, at all times relevant, was covered by

the manufacturer’s warranties (express and implied) subject to the provisions of the California

Lemon Law (California Civil Code § 1790, et seq).

9 At all times relevant, Les Stanford agreed that the place for delivery of the vehicle

io Saberi would be located in San Francisco, California. Therefore, Les Stanford agreed that the

purchase of the Corvette would be subject to the laws of California, including the “Lemon Law.”

10. At all times relevant, Les Stanford agreed io assume responsibility for shipping
the vehicle to Saberi and therefore was the “shipper” for purpose of the Carmack Amendment as

condified at 49 U.S.C. Section 14706, et seq.

10 ll. Saberi is informed and believes that Les Stanford contracted with Defendant BJ

11 Interstate for the purpose of brokering and arranging for shipping the Corveite for delivery to
12 Saberi in San Francisco, California.

12. Saberi is informed and believes that Defendant BJ Interstate brokered and

14 arranged with Safe Auto Transport, a common cartier, to pick up the Corvette from Les Stanford

15 and deliver the Corvette to Saberi in San Francisco, California. Saberi is informed and believes

16 that BJ Interstate failed to discover that Safe Auto Transport was uninsured for delivery to Saberi.

17 13, At all times relevant, based upon Safe Auio Transport’s Case Management

18 Statement dated July 27, 2016, Saberi is informed and believes that Safe Auto Transport was

19 uninsured for any damages alleged herein.

20 14. On or about October 13, 2015, the Corvette was delivered to Saberi in San

21 Francisco, California, by Safe Auto Transport.

22 15. Shortly after the delivery of the Corvette, Saberi discovered that the Corvette was

23 defective and not safe for reasonable operation. In addition, the Corvette had many paint

24 imperfections such as overspray on the windshield. black section of the front bumper and other

25 panels, dullness on the left section of the front lip and on the front bumper. The Corvette was in
26 fact unmerchantable and unfit to be operated. Therefore, the Corvette was not d “new” vehicle as

27 warranted by Les Stanford. Shortly thereafter, Saberi, through his agent, sent photos of the
28 damaged vehicle to Les Stanford and demanded that Les Stanford replace the subject vehicle

2
3
First Amended Complaint for Damages

ee
with a “new” Corvette. On or about November 17, 2015, Mr. Scot Montgomery, General Sales

Manager for Les Stanford. rejected Saberi’s demand.

16. The Corvette was valued, pursuant to the purchase agreement, at $128,391.93,

before delivery to Saberi. If the representations and warranties that Saberi would receive delivery

of a “new” Corveite had been true, the value of the automobile would not have been diminished.

By reason of the acts and events described herein, Saberi has sustained damages in that the

Corvette’s value has been substantially diminished.

17. Upon information and belief, Defendants Les Stanford, BJ Interstate and Safe

Auto Transport based on the allegations herein proximately caused Saberi to incur substantial

10 damages.

1 18. Pursuant to Section 1793.2, subdivision (d), paragraph (2) of the California Civil

12 Code, Saberi demanded that Les Stanford, as the representative of the manufacturer and as the

seller of the Corvette,that Les Stanford promptly replace the new Corvette or repay Saberi the

14 sum of $128,391.93.

15 19, By reason of Les Stanford’s failure and refusal to promptly replace the new

16 Corvette or pay restitution, Saberi has been required to incur attorney’s fees and costs to pursue

7 ihe claims alleged herein.
18 TL
FIRST CAUSE OF ACTION
19 For Violation of the Song-Beverly Consumer Warranty Act
Civil Code §1790, et seq., also known as “Lemon Law”
20 Against Defendant Les Stanford
21

22 20. Saberi incorporates by reference all of the allegations contained in paragraphs 1 to

23 19 as set forth above.

24 21. Defendant Les Stanford violated the Song-~Beverly Consumer Warranty Act (Civil

25 Code § 1790, et seq.), including the requirement to deliver the “new” Corvette to conform to the
26 applicable implied and express warranties alleged in paragraph 7. Defendants should promptly

27 replace the new Corvette (Civil Code § 1793.2(d)(2)) or repay Saberi the sum of $128,391.93,

28 plus interest, including attorney’s fees and costs.

4
First Amended Complamt or Damages
222. Plaintiff Saberi requests a civil penalty in an amount at least two times the amount

of actual damages.

WHEREFORE, Plaintiff prays for judgment as hereinafter set forth.

Iv.
SECOND CAUSE OF ACTION
Breach of Written Contract Against Defendant Les Stanford

23. Plaintiff Saberi incorporates by reference all of the allegations contained in
paragraphs 1 to 22 as set forth above.
24. Les Stanford, in the Vehicle Purchase Order attached as Exhibit A, represented to

10 Saberi that the Corvette was of merchantable quality and fit for the purpose intended to be driven

ll and operated as a “new” vehicle. Saberi reasonably relied on the aforesaid representations and
12 performed all of his obligations pursuant to Vehicle Purchase Order; including payment of

13 $128,391.93.

14 25. Les Stanford breached its contractual obligations alleged herein causing Saberi

15 damages in the sum of $128,391.93, plus interest, including attorney’s fees and costs.

16 WHEREFORE, Saberi prays for judgment as hereinafter set forth.

17 Vv.
THIRD CAUSE OF ACTION
18 Carmack Amendment Allegations Against Safe Auto Transport
19 26. Plaintiff Saberi incorporates by reference all of the allegations contained in
20 paragraphs | to 19 as set forth above.
21 27. This cause of action is against Safe Auto Transport, as the common carrier,
22
subject to the provisions in 49 U.S. Code Section 14706. According to Section 14706(d)(1) and
23 (3) this civil action may be brought against Safe Auto Transport in this court.
24 28. Upon information and belief, Les Stanford, as the shipper, delivered the Corvette
25 to Safe Auto Transport in good condition. Thereafter, the Corvette was delivered to Saberi in
26 damaged condition. The amount of damages caused by the loss is $128,391.93, plus interest,
27 attorney's fees and costs.
28 WHEREFORE, Saberi prays for judgment as hereinafter set forth.

<
3
First Amended Complaint for Damages
,
ff
Vi
FOURTH CAUSE OF ACTION
Negligence Against Defendant BJ Interstate

29. Plaintiff Saberi incorporates by reference ali of the allegations contained in

paragraphs | to 19 as set forth above.

30. At all times relevant herein, BJ Interstate owed a duty of care to Les Stanford and

Saberi that Safe Auto Transport was properly insured regarding the pick-up and delivery to

Saberi.

31. At all times relevant herein, Saberi is informed and believe that Safe Auto
10
Transport was uninsured for the damages alleged herein.
iW
32. BJ Interstate breached its duty of care to Les Stanford and Saberi as described in
12
paragraphs 9 to 19, causing damage to Saberi as alleged.

WHEREFORE, Plaintiff prays for judgment as follows:
14
1 For the First Cause of Action, Saberi is entitled to a new Corvette and damages,
15 .
including restitution and attorney’s fees and costs;
16 22. For the Second Cause of Action, Saberi is entitled to damages, according to proof.
17
3 For the Third Cause of Action, Saberi is entitled to damages including the full
18 actual loss fair market value of the Corvette at the place of its destination in San Francisco;
19 4 For the Fourth Cause of Action, Saberi is entitled to damages, according to proof:
20
5 For attorney’s fees and costs allowed by law;
21
6 For prejudgment interest; and
22 7
ay be’ a] ropriate.
For such other and further relief

DATED: October \& 2016.
24
25
JAMES M,/DOMBROSK1
26 Attorney ‘or Plaintiff Andy Saberi
27
28

6
First Amended Complaint jor Damages
re ¢ ~
CONDENSED
’

In the Matter Of:

ANDY SABERI vs LES STANFORD CHEVROLET CADILLAC
CIV-536294

BOGDAN DEDYK

March 09, 2018
ee Volume I

ESQ UIRE
DEPOSITION SOLUTIONS
800.21 1.DEPO (3376)
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Cs Exhibit.2
BOGDAN DEDYK Volume | March 09, 2018
ANDY SABERI vs LES STANFORD CHEVROLET CADILLAC 1-4
ge T ge
os SUPERIOR COURT OF THE STATE OF CALIFORNIA INDEX TO EXAMINATION
IN THE COUNTY OP SRN MATEO
ANDY SABERI, CASE NO, CIV-536294 WITNESS: BOGDAN DEDYK, VOLUME I
Plaintife, EXANINATION PAGE
ve By Mr. Dorbroski
LES STANFORD CHEVROLET CADILLAC,
tee
INC., a Michigan’ corporation, BJ INTERSTATE
AUTO TRANSPORTERS, INC., a Nevada
corporation, BOGDAN DEDYK, doing business INDEX TO EXHIBITS
MARKED PAGE
as SAFE AUTO ‘TRANSPORT, en individual, FOR THE PLAINTIFF. (2) Amended Notic
and DOES 1 through 25, inclusive,, (2) Bscimate Total’
10 (3) Proof of Hand Delivery. a
10 Defendants. (4)Piret Anended Complaint 23
n (5}Crops Complaint 23
2 DEPOSITION OF BOGDAN DEDYK (6) Cross Complaint 23
B VOLUME I 22 (n)Deciavation of Bogdan Dedjk 50
4 MARCH 05, 2016 {8)Reaponse to Plaintift tee 83
2:24 a.m, 3
16 2181 River Plaza Drive, Suite 300 FOR THE DEFENDANTS. .NONE WERE PRESENTED
nv Sacramento, California 95833 a
18 as
a6
uw
20 18
BL 19
22 20
23 2.
Reported by: 22
20 THERESA R. PERRY, COR 23
CSR License No. 12744 24
28 28
os
Pagez Page 4
APPEARANCES SACRAMENTO, CALIFORNIA
FRIDAY, MARCH 09, 2018, 11:24 a.m.
For Plaintiff: BOGDAN DEDYK,
LAW OFFICES OF JAMES M. DOMBROSKI, LLP
SAMES M. DOMBROSKI, BEQ. having been first duly sworn, was examined and
Post Office Box 751027 1s testifies as follows:
Petaluma, California 94975
EXAMINATION
BY MR. DOMBROSKI: Good morning.
For Defendante: THE WITNESS: jood morning.
8
‘TOscHT, SIDRAN, COLLINS & DOYLE Q. BY MR. DOMBROSKI: I'm Jim Dombroski, | represent
9 THOMAS CROWELL, Beg 10 Andy Saber! in this case. Have you had your deposition
$145 Johnson Drive W taken before?
10 Pleasanton, California 94588
aa. LeVANGIE LAW GROUP 12 A. Uh, no.
MICHAEL LE VANG?: » Beq. 13 Q. And | assume you recall counsel explained the
22 2021 N, Street 14 purpose of a deposition?
Sacramento, California 95842
13 15 A. J guess.
LAW OFFICES OF JAMES ATTRIDGE 16 Q. And just so it's clear, basically one of the
a4 JAMES ATTRIDGS, Esq
270 Divisadero Street, Suite 3 17 tacts -- purpose is fact gathering. To gather the facts
as San Francisco, California 94117 18 as brought fo the case and also for purposes of
1s 19 recording your testimony for potentially being used In a
a7 Itigatlon. Either In terms ot pretrial purposes or
18 20
a9 21 ‘trial.
20 22 So you're going to have an opportunity to review
a
22 23 the transcript after the court reporter finishes It and
23 24 make corrections if necessary. But If you make
2
25 corrections, we have the right to ask that you explain

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BOGDAN DEDYK Volume } March 08, 2018
ANDY SABERI vs LES STANFORD CHEVROLET CADILLAC 73-76
f Page? Page 75
ia {wanted to cover, But i'm going to be jumping around a { 1 Q BY MR. ATRIDGE: How did you find him?
lot, So | apologize for that -- if these questions don’t i{ 2 MR. GROWELL: The first guy?
5 MR. ATRIDGE: Yes.
sound like their in sequence.
How many times prior to this move did you carry THE WITNESS: | guess someone referred him.
Joads booked by BY Interstate just your best estimate? Q. BY MR. ATRIDGE: Had you deait with him before?
A. Don't know. A, No,
Q. Would it have been more than ten? Q. Tim going 10 talk to you now about a couple of
A. Don't know, sir. questions just about your personal experience. Have you
Q. When Mr, Crowell relersed to the website and you g ever driven a car catcher? Have you ever transported
10 reter to it as weil, does the word “load/board*, have 10. automobiles yourself?
uw you ever heard the word “load’board” used in reference | 14 AL Yes.
12 to those? 142 Q. Has it been your experience when driving that you
13 A No. 113 occasionally have to provide information to police
14 Q. Prior to the first time Bu Interstate - I'll 14 Gfiicers like CHP or the highway patrol in given
18 strike that. Ht15 interstate? Have they ever pulled you over and asked
16 When. if ever, was the first time you acvised Bu fie for information?
7 Interstate of the damage? V7 A. Yes.
18 A. After | heard from the driver. 18 Q. Andis it your experience thal they normally ask
19 Q. And !'m going to refer you to this information jie you for registration and insurance?
20 which appears on pages 48 through 51 of the second 20 A. Yes.
at exhibit. Bid you have to furnish proof of your 21 Q. Has there ever been an occasion where you were
22 Insurance to the Federal Motor Carrier Safety 22 unabie to provide your Insurance to an officer?
Administration? A. No.
24 A. Yes. lea Q. Have there ever been a time since you have besa
25 Q. Did you have to do it before you got your license [25 operating Safe Auto Transport that you have been
~ — ”
Page ts Page 76
as a condition of getting a permit? uninsured?
A. Yes. 2 A. No.
Q. ‘And have you evar had your permit suspended for not Q, Let me show you paragraph 13, okay.
having insurance? MR. LE VANGIE: So we're looking at the complaint?
A. No, MR. ATRIDGE: The first amended complaint
Q. And again, | might be covering some ground that has MR. LE VANGIE: We'rs fooking at the first amended
already been covered. |'m clearing up a few loose ends. complaint which | believe was marked Exhibit 4 paragraph
As you sit hare today, okay, when did you first find out 42, is an allegation by the Saberis in that complaint.
you were sued? Go ahead.
10 A. Beginning of 2016. { 10 Q, BY MS. ATRIDGE: Could you please read that
n Q. And when you found out you were sued, what was the V4 paragraph for me and let me know when you're done
12 first thing you did in connection with that, how did you !
142 reading it.
13 respond? 43 THE WITNESS: Which one?
14 A. Gail insurance agency. 414 MR. LE VANGIE: Thirteen,
46 Q. Okay. And that was the broker truck network truck, (18 MS. ATRIDGE: Under the lined stuff.
is that who you called? i4 + (Pause in the proceedings,)
6
AL Yes. 447 THE WITNESS: Okay.
18 Q. Did you ever call Great Lakes or any other 18 Q. BY MR, ATRIDGE: Is it an accurate statement that
19 insurance company instead of the broker? 1g at the time of this event you were uninsured?
A. Don't remember. 20 MR. LE VANGIE: Aocurate or inaccurate?
ay Q, How did you get a hold of that lawyer, the first 21 @. BY MS. ATRIDGE: Is it accurate thar you were
22 lawyer, the fellow with tho -- 22 uninsured?
MR. LE VANGIE: Where ara we going? The fas MR. LE VANGIE: You were uninsured as July 27th,
-- a4 atlorney/elient most of the responses ~- how did you 24 2016, correct?
25 find is probably fine. 25 THE WITNESS: Yes.

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BOGDAN DEDYK Volume | March 09, 2018
ANDY SABERI vs LES STANFORD CHEVROLET CADILLAC 85-86
Page 5 |
STATE CF CALESORNEA
38.
MINTY OP SACREMENTOS

i Perry, Cert. ed Shorthand Reportec.
do hereby cercify:
That ‘ior te being exenin he witness in the
goragoing proceedings was by me y svora to testify to
he h, the whole truth end nechiag but the truth,
‘That said proceedings ve: teken before a2 ar che
10 tine and place here: tet forth, and were taken doxn by
we in shorthand and thereafter transe: 1s into
a2 typeeriting under py direction and supervision;
a 1 further certify thar am neither counsel for.
uM nor related ce, any parties co said procesdings, nor in
15 anyuise invevesced Ln the ourcone therecf.
jtness vherect. + have her ve subscribed my
Ww
fae
ae Bate March 15, 2018
36
23 ren? Pon,
Theresa 2. Percy
SR No, 12784
2a
34
38
—— Rags ws
DEPOSITION ERRATA 6:
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Reason for chang
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change:
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AOGDAN DEDYR
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~
April 26, 2018

Dombroski, James
Law Office Of James M Dombroski - Petaluma
P.O, Box 751027
Petaluma, CA 94975

Case: Andy Saberi vs. Les Stanford Chevrolet Cadillac Inc et al
Deposition of: Bogdan Dedyk
Proceeding. Date: 03/09/2018
Our Assignment No.: 31349124

Dear Sir or Madam,

Enclosed please find the Original deposition wanscript in the above referenced matter and any
Original Exhibits which remained in our custody. Th¢ documents enclosed should complete the
deliverables for your order. We did not receive completed Errata from the witness within the
specified time limit. If, at a later day, we do receive a completed set of forms, our policy is to
digitally archive as usual and make the changes available in electronic form to all counsel.
If you have any questions, please contact Esquire Client Support at 800.211.DEPO, or
ClientCare@esquiresolutions.com.
Thank you,

Errata Processing Division
Corporate Production Department
Esquire Deposition Solutions

Enclosures

Ce: All Counsel present

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Ex it3
ie =:
BOGDAN DEDYK Volume | March 09, 2018
ANDY SABERI vs LES STANFORD CHEVROLET CADILLAC 85
os STATE OF CALIFORNIA )
) ss.
COUNTY OF SACRAMENTO)

I, Theresa R. Perry, Certified Shorthand Reporter,

do hereby certify:

That prior to being examined, the witness in the

foregoing proceedings was by me duly sworn to testify to

the truth, the whole truth and nothing but the truth;

That said proceedings were taken before me at the

10 time and place herein set forth, and were taken down by

at me in shorthand and thereafter transcribed into

12 typewriting under my direction and supervision;

, ~ 13 I further certify that I am neither counsel for,

14 nor related to, any parties to said proceedings, nor in

15 anywise interested in the outcome thereof.

16 In witness whereof, I have hereunto subscribed my

17 name.

19 Dated: March 19, 2018

21
Mrs rare. 2 Paro
Theresa R. Perry
22 CSR No. 12744

os 25

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a ~
fe
Exhibit “{
a

Case Info

Judge

John L. Grandsaert Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

October 05, 2018

Case Filing Date

November 18, 2015

County

Parties

ATTRIDGE, JAMES Attorneys for Defendants
ATTRIDGE, JAMES Attorney for the Defendant
BJ INTERSTATE AUTOTRANSPORTERS, INC Cross Defendant
BJ INTERSTATE AUTOTRANSPORTERS, INC Defendant
DEDYK, BOGDAN Cross Defendant
DEDYK, BOGDAN Defendant
DOES 1 TO 25 Cross Defendant
DOMBROSKI, JAMES M. Attorney for the Plaintiff
LES STANFORD CHEVROLET CADILLAC, INC Cross Complainant
LES STANFORD CHEVROLET CADILLAC, INC Defendant
LEVANGIE, MICHAEL J Attorneys for Defendants
LEVANGIE, MICHAEL J Attorney for the Defendant
SABERI, ANDY Plaintiff
SIDRAN, DAVID ROBERT Attorney
SIDRAN, DAVID ROBERT Attorney for the Defendant
Thomas Crowell Attorney
Alexander Millington Attorneys for Defendants
Thomas Saberi Attorneys for Plaintiffs
Jason Yang Attorneys for Defendants
Kerri Rollins Attorneys for Defendants
Michael Lee Attorney
Shawn Loorz Attorneys for Plaintiffs
Thomas Mawn Attorney
Michael Langs Attorneys for Defendants
Dmitriy Shchebenko Attorney
Steven Soltman Attorney

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Motion-Secondary: ANDY SABERI VS LES STANFORD, ETAL

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