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Soheyl Tahsildoost (Bar No. 271294)
Kainoa. Aliviado (Bar No. 308382) ED
THETA LAW FIRM, LLP SUPERIOR COURT OF CALIFORNIA
15901 Hawthorne Blvd., Suite 270 SOUNEY OF ERAGER
Lawndale, CA 90260 :
Telephone: (424) 297-3103 JAN 2018
Facsimile: (424) 286-2244 JAKE TERS
BS
EXECUTIVE OFFICER & CLERK
Attorneys for defendant Hyundai Motor America By: E. Cavazos, Deputy
TR
DN
SS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CO
COUNTY OF PLACER
So
ANNA P. KING, Case No.: SCV0038637
SmtSet”
11 Plaintiff, SUPPLEMENTAL DECLARATION OF
St!
SOHEYL TAHSILDOOST REGARDING
ete
12 VS. ADDITIONAL
een” See!
SANCTIONS AGAINST
PLAINTIFF AND HER COUNSEL IN
13 HYUNDAI MOTOR AMERICA, a SUPPORT OF DEFENDANT HYUNDAI
Nese! See” See”
California Corporation, and DOES 1 MOTOR AMERICA’S MOTION TO
14 through 10, inclusive, COMPEL PRODUCTION OF PLAINTIFF’S |
VEHICLE FOR INSPECTION
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15 Defendants.
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Dept.: 40
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16 Judge: Commissioner Michael A. Jacques
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Date: February 6, 2018
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17 Time: 8:30 a.m.
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18 Complaint Filed: October 28, 2016
See”
Trial Date: None
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19
Named
20 TO THE COURT AND TO PLAINTIFF AND THEIR ATTORNEYS OF RECORD:
21 PLEASE TAKE NOTICE that Defendant Hyundai Motor America (“Defendant” or
22 “HMA”) hereby submits the following Supplemental Declaration of Soheyl Tahsildoost
23 regarding additional sanctions against Plaintiff and her counsel (“Supplemental Declaration’) in
24 support of its ation to compel the production of Plaintiff's vehicle for inspection and for an
25 award of sanctions (“Motion”). The Honorable Commissioner Michael A. Jacques continued the
26 hearing on HMA’s Motion to February 6, 2018 so that HMA could submit this Supplemental
27 CAUSERS\SOHEY\DESKTOP\SUPPLEMENTAL
DECL.
OF SOHYLTAHSILDOOSTRE 1 SANCTIONS.DOCX
28 REGARDING
SUPPLEMENTAL DECLARATION OF SOHEYL TAHSILDOOST
ADDITIONAL SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN
- SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA’S MOTION TO COMPEL
PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION
© )
Declaration.
Dated: January 22, 2018 THETA LAW FIRM, LLP
Bos
SOHEYL TAHSILDOOST
Attorneys for Defendant Hyundai Motor America
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27 TAHSILDOOSTRE DUCE
‘SANCTIONS:
OF
DECL.,
CAUSERS\SOHEY\DESKTOP\SUPPLEMENTAL SOHYE
28 OF SOHEYL TAHSILDOOST REGARDING
SUPPLEMENTAL DECLARATION
ADDITIONAL SANCTIONS AGAINST PLAINTIF F AND HER COUNSEL IN
SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA ’S MOTION TO COMPEL
PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION
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SUPPLEMENTAL DECLARATION OF SOHEYL TAHSILDOOST
L, Soheyl Tahsildoost, declare as follows:
1. I am a partner in the law firm of Theta Law Firm, LLP, attorneys of record for
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Defendant Hyundai Motor America. If called as a witness, I could and would competently
testify under oath to the following facts of which I have personal knowledge.
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2. Prior to the inspection, I booked a hotel for the night of December 28 so that I
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could stay in Sacramento between the day of the deposition, December 28", and the day of the
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scheduled vehicle inspection, December 29". Upon plaintiff's counsel’s notice of their refusal to
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proceed with the vehicle inspection, I attempted to get a flight back on the night of the 28", but
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there were no flights back, so I stayed in Sacramento on the 29".
11 3. I did not receive a firm confirmation of the rescheduled vehicle inspection until
12 January 16, 2018. That same day, I attempted to book flights through Expedia, and found no
13 flights back from Sacramento to LAX (except for some flights that involved stops and would
14 have taken longer than six hours). I then tried American Airlines, and found no return flights
15 available other than first class flights. Ithen decided to book a rental car and drive up the night
16 of the 17" for the VI on the 18" because I was not able to find flights.
17 4. The cost of the rental car from Enterprise, gas (including three fill-ups) that my
18 firm paid was $324.83. The cost of the one-night hotel stay at Fairfield Inn & Suites Sacramento
19 Elk Grove that my firm paid was $210.90. Both of these costs will be charged to my client,
20 Hyundai Motor America. Any sanctions awarded in this case reimbursing these amounts will be
21 provided to Hyundai Motor America.
22 I declare under penalty of perjury under the laws of the State of California that the
23 foregoing is true and correct.
Lawndale, California.
LZ
24 Executed on January 22, 2018 at
25
26
SOHEYL TAHSILDOOST
27 OF
DECL. SOHYLTAHSILDOOSTRE 3 SANCTIONS.DOCX
CAUSERS\SOHEY\DESKTOP\SUPPLEMENTAL
28 SOHEYL TAHSILDOOST REGARDING
SUPPLEMENTAL DECLARATION OF
ADDITIONAL SANCTIONS AGAINST PLAINTIFF AND HER COUNSE L IN
SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA’S MOTION TO COMPEL
PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION
© oO
PROOF OF SERVICE
(Code Civ. Proc., § 1013a(3) Revised 5-1-88)
Tam over the age of 18, not a party to this action, and employed in the county where this mailing
occurred. My business address is 15901 Hawthorne Blvd., Suite 270, Lawndale, CA 90260. On
January 22, 2018, I served the following documents described as DEFENDANT HYUNDAI
MOTOR AMERICA’S REPLY IN SUPPORT OF ITS MOTION TO COMPEL THE
PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION AND FOR AN
AWARD OF SANCTIONS; DECLARATION OF SOHEYL TAHSILDOOST on interested
parties in this action by placing original/true copies thereof in sealed envelopes addressed as
‘ollows:
Steve Mikhov Bryan C. Altman
“sD
Amy Morse Altman Law Group
Knight Law Group 6300 Wilshire Blvd., Suite 980
1801 Century Park East, Suite 2300 Los Angeles, CA 90048
Los Angeles, CA 90067 (323) 653-5581 Phone
fe
(310) 552-2250 Phone (323) 653-5542 Fax
oOo
(310) 552-7973 Fax
[| BYMAIL: I deposited such envelope in the mail at Lawndale, California. The envelope
was mailed with proper postage thereon fully prepaid. I am “readily familiar" with the firm's
1 practice of collection and processing correspondence for mailing. Said mailing is deposited with
the United States Postal Service on that same day in the ordinary course of business and there is
12 delivery service by United States mail atthe place so addressed. Iam aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter date is
13 more than one day after date of deposit for mailing in affidavit.
14 CL] BY PERSONAL SERVICE: I delivered such envelope by hand to the individual(s) listed
on the above service list. =
15
Cl BY ELECTRONIC TRANSMISSION: I caused to be electronically transmitted such
16 document referenced above to the individual(s) listed on the above service list.
17 CT BY FACSIMILE TRANSMISSION: I transmitted the facsimile to the individual(s)
listed on the above service listat the facsimile number listed thereon. The telephone number on
18 the facsimile machine I used is (424) 286-2244. The facsimile machine I used complied with
Rule 2.306 and no error was reported by the machine. Pursuant to Rule 2.306, I caused the
19 machine to print a transmission record of the transmission, a copy of which isattached to this
declaration.
20
XxX BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package
21 provided by an overnight delivery carrier and addressed to the person atthe above-address. 1
placed the envelope or package for collection and overnight delivery at an office or a regularly
22 utilized drop box of the overnight delivery carrier.
23 I declare under’ penalty of perjury under the laws of the State of California that the above
is true and correct, Executed on January 22, 2018 at Lawndale, California.
24
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26 Steven Correa
27 CAUSERS\SOHE
Y\DESKTOP\SUPPLEMENTAL
DECL.OFSOHYLTAHSILDOOSTRE gees DOCX
28 DECLARATION OF SOHEYL TAHSILDOOST REGARDING
SUPPLEMENTAL
ADDITIONAL SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN
SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA’S MOTION TO COMPEL
PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION
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Soheyl Tahsildoost (Bar No. 271294) Kainoa. Aliviado (Bar No. 308382) ED THETA LAW FIRM, LLP SUPERIOR COURT OF CALIFORNIA 15901 Hawthorne Blvd., Suite 270 SOUNEY OF ERAGER Lawndale, CA 90260 : Telephone: (424) 297-3103 JAN 2018 Facsimile: (424) 286-2244 JAKE TERS BS EXECUTIVE OFFICER & CLERK Attorneys for defendant Hyundai Motor America By: E. Cavazos, Deputy TR DN SS SUPERIOR COURT OF THE STATE OF CALIFORNIA CO COUNTY OF PLACER So ANNA P. KING, Case No.: SCV0038637 SmtSet” 11 Plaintiff, SUPPLEMENTAL DECLARATION OF St! SOHEYL TAHSILDOOST REGARDING ete 12 VS. ADDITIONAL een” See! SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN 13 HYUNDAI MOTOR AMERICA, a SUPPORT OF DEFENDANT HYUNDAI Nese! See” See” California Corporation, and DOES 1 MOTOR AMERICA’S MOTION TO 14 through 10, inclusive, COMPEL PRODUCTION OF PLAINTIFF’S | VEHICLE FOR INSPECTION eee 15 Defendants. ee” Dept.: 40 eee” 16 Judge: Commissioner Michael A. Jacques Nene! Date: February 6, 2018 ane 17 Time: 8:30 a.m. Neem” Se” 18 Complaint Filed: October 28, 2016 See” Trial Date: None eee 19 Named 20 TO THE COURT AND TO PLAINTIFF AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE that Defendant Hyundai Motor America (“Defendant” or 22 “HMA”) hereby submits the following Supplemental Declaration of Soheyl Tahsildoost 23 regarding additional sanctions against Plaintiff and her counsel (“Supplemental Declaration’) in 24 support of its ation to compel the production of Plaintiff's vehicle for inspection and for an 25 award of sanctions (“Motion”). The Honorable Commissioner Michael A. Jacques continued the 26 hearing on HMA’s Motion to February 6, 2018 so that HMA could submit this Supplemental 27 CAUSERS\SOHEY\DESKTOP\SUPPLEMENTAL DECL. OF SOHYLTAHSILDOOSTRE 1 SANCTIONS.DOCX 28 REGARDING SUPPLEMENTAL DECLARATION OF SOHEYL TAHSILDOOST ADDITIONAL SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN - SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA’S MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION © ) Declaration. Dated: January 22, 2018 THETA LAW FIRM, LLP Bos SOHEYL TAHSILDOOST Attorneys for Defendant Hyundai Motor America NN sa Oo \o li 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 TAHSILDOOSTRE DUCE ‘SANCTIONS: OF DECL., CAUSERS\SOHEY\DESKTOP\SUPPLEMENTAL SOHYE 28 OF SOHEYL TAHSILDOOST REGARDING SUPPLEMENTAL DECLARATION ADDITIONAL SANCTIONS AGAINST PLAINTIF F AND HER COUNSEL IN SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA ’S MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION aenn nan oO 0 SUPPLEMENTAL DECLARATION OF SOHEYL TAHSILDOOST L, Soheyl Tahsildoost, declare as follows: 1. I am a partner in the law firm of Theta Law Firm, LLP, attorneys of record for Ww Defendant Hyundai Motor America. If called as a witness, I could and would competently testify under oath to the following facts of which I have personal knowledge. NN 2. Prior to the inspection, I booked a hotel for the night of December 28 so that I DR could stay in Sacramento between the day of the deposition, December 28", and the day of the tN scheduled vehicle inspection, December 29". Upon plaintiff's counsel’s notice of their refusal to Co proceed with the vehicle inspection, I attempted to get a flight back on the night of the 28", but so there were no flights back, so I stayed in Sacramento on the 29". 11 3. I did not receive a firm confirmation of the rescheduled vehicle inspection until 12 January 16, 2018. That same day, I attempted to book flights through Expedia, and found no 13 flights back from Sacramento to LAX (except for some flights that involved stops and would 14 have taken longer than six hours). I then tried American Airlines, and found no return flights 15 available other than first class flights. Ithen decided to book a rental car and drive up the night 16 of the 17" for the VI on the 18" because I was not able to find flights. 17 4. The cost of the rental car from Enterprise, gas (including three fill-ups) that my 18 firm paid was $324.83. The cost of the one-night hotel stay at Fairfield Inn & Suites Sacramento 19 Elk Grove that my firm paid was $210.90. Both of these costs will be charged to my client, 20 Hyundai Motor America. Any sanctions awarded in this case reimbursing these amounts will be 21 provided to Hyundai Motor America. 22 I declare under penalty of perjury under the laws of the State of California that the 23 foregoing is true and correct. Lawndale, California. LZ 24 Executed on January 22, 2018 at 25 26 SOHEYL TAHSILDOOST 27 OF DECL. SOHYLTAHSILDOOSTRE 3 SANCTIONS.DOCX CAUSERS\SOHEY\DESKTOP\SUPPLEMENTAL 28 SOHEYL TAHSILDOOST REGARDING SUPPLEMENTAL DECLARATION OF ADDITIONAL SANCTIONS AGAINST PLAINTIFF AND HER COUNSE L IN SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA’S MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION © oO PROOF OF SERVICE (Code Civ. Proc., § 1013a(3) Revised 5-1-88) Tam over the age of 18, not a party to this action, and employed in the county where this mailing occurred. My business address is 15901 Hawthorne Blvd., Suite 270, Lawndale, CA 90260. On January 22, 2018, I served the following documents described as DEFENDANT HYUNDAI MOTOR AMERICA’S REPLY IN SUPPORT OF ITS MOTION TO COMPEL THE PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION AND FOR AN AWARD OF SANCTIONS; DECLARATION OF SOHEYL TAHSILDOOST on interested parties in this action by placing original/true copies thereof in sealed envelopes addressed as ‘ollows: Steve Mikhov Bryan C. Altman “sD Amy Morse Altman Law Group Knight Law Group 6300 Wilshire Blvd., Suite 980 1801 Century Park East, Suite 2300 Los Angeles, CA 90048 Los Angeles, CA 90067 (323) 653-5581 Phone fe (310) 552-2250 Phone (323) 653-5542 Fax oOo (310) 552-7973 Fax [| BYMAIL: I deposited such envelope in the mail at Lawndale, California. The envelope was mailed with proper postage thereon fully prepaid. I am “readily familiar" with the firm's 1 practice of collection and processing correspondence for mailing. Said mailing is deposited with the United States Postal Service on that same day in the ordinary course of business and there is 12 delivery service by United States mail atthe place so addressed. Iam aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is 13 more than one day after date of deposit for mailing in affidavit. 14 CL] BY PERSONAL SERVICE: I delivered such envelope by hand to the individual(s) listed on the above service list. = 15 Cl BY ELECTRONIC TRANSMISSION: I caused to be electronically transmitted such 16 document referenced above to the individual(s) listed on the above service list. 17 CT BY FACSIMILE TRANSMISSION: I transmitted the facsimile to the individual(s) listed on the above service listat the facsimile number listed thereon. The telephone number on 18 the facsimile machine I used is (424) 286-2244. The facsimile machine I used complied with Rule 2.306 and no error was reported by the machine. Pursuant to Rule 2.306, I caused the 19 machine to print a transmission record of the transmission, a copy of which isattached to this declaration. 20 XxX BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package 21 provided by an overnight delivery carrier and addressed to the person atthe above-address. 1 placed the envelope or package for collection and overnight delivery at an office or a regularly 22 utilized drop box of the overnight delivery carrier. 23 I declare under’ penalty of perjury under the laws of the State of California that the above is true and correct, Executed on January 22, 2018 at Lawndale, California. 24 25 26 Steven Correa 27 CAUSERS\SOHE Y\DESKTOP\SUPPLEMENTAL DECL.OFSOHYLTAHSILDOOSTRE gees DOCX 28 DECLARATION OF SOHEYL TAHSILDOOST REGARDING SUPPLEMENTAL ADDITIONAL SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN SUPPORT OF DEFENDANT HYUNDAI MOTOR AMERICA’S MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S VEHICLE FOR INSPECTION