On April 14, 2015 a
Party Statement
was filed
involving a dispute between
Gurraj Grewal,
Sonora Gasoline Corporation,
Voyager Restaurant Group, Inc.,
and
2012-Sip-1 Venture Llc,
Gurraj Grewal,
Nirmal Singh,
Parneet , Doe 2 Parmar,
Roseville Petroleum, Inc.,
Sabal Financial Group Lp,
Sonora Gasoline Corporation,
Sonora Petroleum, Inc.,
Tennessee Commerce Bank,
for civil
in the District Court of Placer County.
Preview
1 PAUL A. WARNER, ESO. _(SBN 112168) ‘supehy LL EDaie
>| 1624 Santa Clara Drive, Suite 220 County of Placer
“ |Roseville, CA 95661 ‘
. 3 | Telephone: (916) 996-3100 “ial 01 2018
_ | Facsimile: (916) 789-7557 -
Z Attorneys for Plaintiff Voyager Restaurant Group, Inc.
7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 "IN AND FOR THE COUNTY OF PLACER
Ao VOYAGER. 2 RESTAURANT GROUP, INC., Case No. S-CV-0035599
ila California corporation i 7 . ae
. DECLARATION OF PAUL WARNER IN _
12 |. Plaintiff SUPPORT OF MOTION FOR AN ORDER
y . TO CONTINUE TRIAL AND RE- ‘OPEN .
13} | DISCOVERY |
SONORA GASOLINE CORPORATION, a
14 .
-| California corporation formerly known as. .
15 | SONORA PETROLEUM, INC., a California. Date: March 8, 2018
S corporation, GURRAJ SINGH GREWAL, | ‘Time: 8:30 a.m.
16 | SABAL FINANCIAL GROUP LP, a Dept.: 43
7 _| Delaware limited partnership; 2012-SIP-1
VENTURE LLC, a Delaware limited liability; _.
18 company as successor to TENNESSEE En Date: March 19, 2018
_-| COMMERCE BANK, a Tennessee State “ aie avy »
19 | chartered bank, ROSEVILLE PETROLEUM, Si. {ae -
| INC., a California corporation, NIRMAL
20 | SINGH, and DOES ONE through TWENTY,
inclusive, .
21
2 - Defendants.
23 |
oH ~ I, Paul Warner, declare:
5° [am an attorney licensed to practice in the State of California and am attorney of record for
26 | Plaintiff Voyager Restaurant Group, Inc., herein. Ihave personal knowledge of each fact stated —
:
||
} 27 l | |
DECLARATION OF PAUL WARNER IN SUPPORT | OFMOTION FOR AN ORDER TO CONTINUE TRIAL - .
|: ; 28
f ne AND RE-OPEN DISCOVERY "3
CO }
in this declaration except for those matters stated on information and belief, and as to those
matters, Iam informed and believe them to be true.
Wo NN
1. On January. 26, 2018, I was informed by email from Julie Steiner that her father, Jack
Burstein, had unexpectedly passed that morning. .
Bm
2.. Previously, in communication with Mr. Burstein on January 4, 2018, he had requested an
Ww
HD
extension of time to provide discovery documents. —
NI
3. On January 18, 2018, Mr. Burstein had indicated that his client would be available for
Oe
deposition in my office on February 5, 2018.
4.0
10 4. On January 29, 2018, counsel for Defendants Roseville Petroleum, Inc., and Nirmal Singh,
i indicated that his clients’ depositions for January 30 and/or 31,-2018, should be postponed
12 considering Mr. Burstein’s demise. . .
13
5. On February 16, 2018, in response to my query as to the status of replacement counsel,
14
Donna Kenney of Mr. Burstein’s administrative staff, requested an extension of time until
15
April 3, 2018, to respond to a cross-complaint in a related matter.
16
6. Counsel for Defendants Roseville and Grewal does not object to a continuance but may
17
18 have concerns about re-scheduling,
‘19 7. Counsel for Defendants Roseville and Grewal agreed to cooperate regarding discovery.
20 8. Ihave been informed that Mr. Burstein’s clients have been notified to seek new counsel.
21 I declare under penalty of perjury under the laws of the State of California. that the
2
foregoing is true and correct wll
23
DATED: 4 UL fy t Rae cas
24
25
26
a 2 -
DECLARATION CONTINUE
28 OF PAUL WARNER IN
AND
SUPPORT
RE-OPEN
OF MOTION
DISCOVERY
FOR AN ORDER TO TRIAL
Preview
1 PAUL A. WARNER, ESO. _(SBN 112168) ‘supehy LL EDaie >| 1624 Santa Clara Drive, Suite 220 County of Placer “ |Roseville, CA 95661 ‘ . 3 | Telephone: (916) 996-3100 “ial 01 2018 _ | Facsimile: (916) 789-7557 - Z Attorneys for Plaintiff Voyager Restaurant Group, Inc. 7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 "IN AND FOR THE COUNTY OF PLACER Ao VOYAGER. 2 RESTAURANT GROUP, INC., Case No. S-CV-0035599 ila California corporation i 7 . ae . DECLARATION OF PAUL WARNER IN _ 12 |. Plaintiff SUPPORT OF MOTION FOR AN ORDER y . TO CONTINUE TRIAL AND RE- ‘OPEN . 13} | DISCOVERY | SONORA GASOLINE CORPORATION, a 14 . -| California corporation formerly known as. . 15 | SONORA PETROLEUM, INC., a California. Date: March 8, 2018 S corporation, GURRAJ SINGH GREWAL, | ‘Time: 8:30 a.m. 16 | SABAL FINANCIAL GROUP LP, a Dept.: 43 7 _| Delaware limited partnership; 2012-SIP-1 VENTURE LLC, a Delaware limited liability; _. 18 company as successor to TENNESSEE En Date: March 19, 2018 _-| COMMERCE BANK, a Tennessee State “ aie avy » 19 | chartered bank, ROSEVILLE PETROLEUM, Si. {ae - | INC., a California corporation, NIRMAL 20 | SINGH, and DOES ONE through TWENTY, inclusive, . 21 2 - Defendants. 23 | oH ~ I, Paul Warner, declare: 5° [am an attorney licensed to practice in the State of California and am attorney of record for 26 | Plaintiff Voyager Restaurant Group, Inc., herein. Ihave personal knowledge of each fact stated — : || } 27 l | | DECLARATION OF PAUL WARNER IN SUPPORT | OFMOTION FOR AN ORDER TO CONTINUE TRIAL - . |: ; 28 f ne AND RE-OPEN DISCOVERY "3 CO } in this declaration except for those matters stated on information and belief, and as to those matters, Iam informed and believe them to be true. Wo NN 1. On January. 26, 2018, I was informed by email from Julie Steiner that her father, Jack Burstein, had unexpectedly passed that morning. . Bm 2.. Previously, in communication with Mr. Burstein on January 4, 2018, he had requested an Ww HD extension of time to provide discovery documents. — NI 3. On January 18, 2018, Mr. Burstein had indicated that his client would be available for Oe deposition in my office on February 5, 2018. 4.0 10 4. On January 29, 2018, counsel for Defendants Roseville Petroleum, Inc., and Nirmal Singh, i indicated that his clients’ depositions for January 30 and/or 31,-2018, should be postponed 12 considering Mr. Burstein’s demise. . . 13 5. On February 16, 2018, in response to my query as to the status of replacement counsel, 14 Donna Kenney of Mr. Burstein’s administrative staff, requested an extension of time until 15 April 3, 2018, to respond to a cross-complaint in a related matter. 16 6. Counsel for Defendants Roseville and Grewal does not object to a continuance but may 17 18 have concerns about re-scheduling, ‘19 7. Counsel for Defendants Roseville and Grewal agreed to cooperate regarding discovery. 20 8. Ihave been informed that Mr. Burstein’s clients have been notified to seek new counsel. 21 I declare under penalty of perjury under the laws of the State of California. that the 2 foregoing is true and correct wll 23 DATED: 4 UL fy t Rae cas 24 25 26 a 2 - DECLARATION CONTINUE 28 OF PAUL WARNER IN AND SUPPORT RE-OPEN OF MOTION DISCOVERY FOR AN ORDER TO TRIAL