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MC-052
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. state bar umber, and address): FOR COURT USE ONLY
Ronald D. Dessy = (Bar # 96398)
Fawn Kennedy Dessy SBN 90087
Dessy & Dessy, APC, 1301 L Street
Bakersfield, CA 93301
TELEPHONE NO: (661) 322-3863 ___Faxwo: (661) 395-1024
HV Enterprises, a California corporation, THV Hayknarix, LLC, 2 California
ATTORNEY FOR (Name) 1 ted Iealbite, ywand Ligcs uh Defendant:
Name OF couRT:SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
strcet aooress 1415 Truxtun Avenue
MAILING ADDRESS. Same as above
city ano zip cone: Bakersfield 93301
erancu name: Metropolitan Division- Unlimited Civil
CASE NAME: (CASE NUMBER
Aldar Mini Storage, L.P.. vs THV Enterprises, a California corporation, et al., BCV-20-101265-SDS
and Related Cross-Compiaint nearinc Dave: February 2, 2022
DECLARATION IN SUPPORT OF ATTORNEY'S. or H we 8:30am
MOTION TO BE RELIEVED AS COUNSEL—CIVIL serosevenBernard C Barmann, Jr.
pate action sien: Jume 1, 2020
sia. ore May 23, 2022
4. Attorney and Represented Party. Attorney (name): Ronald D. Dessy, Fawn Kennedy Dessy, and Dessy & Dessy, APC
is presently counsel of record for (name of party): Triv Enterprises. a California corporation; THV Hayknarik. LLC, a California limited liability
in the above-captioned action or proceeding. company; and ‘Tigran Arutunyan, Defendants/Cross-Defendants
2. Reasons for Motion. Attorney makes this motion to be relieved as counsel under Code of Civit Procedure section 284(2) instead
of filing a consent under section 284(1) for the following reasons (describe):
Continued on Attachment 2.
3. Service
a. Attorney has
(1) 2) personally served the client with copies of the motion papers filed with this declaration. A copy of the proof of service
will be filed with the court at ieast 5 days before the hearing.
(2) (1 served the client by mail at the client's last known address with copies of the motion papers served with this declaration.
b. If the client has been served by mail at the client's last known address, attorney has
a) confirmed within the past 30 days that the address is current
(a)[_] by mail, return receipt requested.
(b) £7} by telephone.
(c) 2] by conversation,
(a) by other means (specify):
Statement of Information forms filed with California Secretary of State
{Continued on reverse}
Page 1 of 2
ronal Gomciol alta DECLARATION IN SUPPORT OF ATTORNEY'S Goce of Civ Procedure, § 284,
MiC-O82 Rev. Jarry $, 2007] MOTION TO BE RELIEVED AS COUNSEL—CIVIL ve Sort £8 G09
LexisNexis® Automated Califorma Judicial Council FormsMC-052
CASE NAME: CASE NUMBER
Aldar Mini Storage, L.P., vs THV Enterprises, a California corporation, et al., BCV-20-101265-SDS
3. b. (2) Co been unable to confirm that the address is current or fo locate a more current address for the client after making the
following efforts:
(a) [C7] maiting the motion papers to the client's fast known address, return receipt requested.
(b) [-] calling the client's iast known telephone number or numbers.
{c) C3 contacting persons familiar with the client (specify):
(a) [7] conducting a search (describe):
(e) [7] other (specify):
c. Even if attorney has been unabie to serve the client with the moving papers, the court should grant attorney's motion to be
relieved as counsel of record (explain):
4. The next hearing scheduled in this action or proceeding
a. [_] isnot yet set
b. EX] is set as follows (specify the date, time, and place): MSC on 4/19/22, at 1:30pm Dpt. 1, at KCSC, 1415 Truxun Ave.,
Bakersfield, Ca; FCMC on 5/2322, at 9:00am, Div. H at KCSC, 1215 Truxtun Ave., Bakersfield, Ca
¢. [_] concems (describe the subject matter of the hearing):
(_] Continued on Attachment 4
5. The following additional hearings and other proceedings (including discovery matters) are presently scheduled in this case (for each,
describe the date, time, place, and subject matter):
Discovery responses due in about 45 days by THV Enterprises, a California corporation, THV Hayknarik,
LLC, a California limited liability company, and Tigran Arutunyan.
[J Continued on Attachment 5.
6. Trial in this action or proceeding
a. [] is not yet set.
b. is set as follows (specify the date, time, and place): May 23, 2022, at 9:00am, Div. H at KCSC, 1215 Truxtun Ave., Bakersfield, Ca
7. Other, Other matters that the court should consider in determining whether to grant this motion are the following (explain):
i declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: January 4, 2022
Ronald D. Dessy
{T¥PE OR PRINT NAME} (st URE OF DECLARANT)
8. Number of pages attached: 1
MC-O82 [Rew Jonsary 42007 DECLARATION IN SUPPORT OF ATTORNEY'S Page 2 0f2
MOTION TO BE RELIEVED AS COUNSEL—CIVIL
LexisNexis® Automated California Judicial Council FormsAttachments
Attachment 2
This Motion was filed only after the clients were given an opportunity to sign substitutions
of attorney, and did not do so.
Despite numerous efforts, the undersigned has been unable to establish any communication
between Tigran Arutunyan and the undersigned since July of 2021. At the point of the last
communication, Tigran Arutunyan and the undersigned had a difference of perspective on
the manner in which the undersigned should handle certain details related to the case.
Since Tigran Arutunyan has an interest in THV Enterprises, Inc. and HayKnarik, LLC, the
undersigned must also withdraw from the representation of those parties.
Unless the undersigned is able to obtain conflict waiver consent from Tigran Arutunyan to
the undersigned’s continued representation of Khachartur Ghasabyan, the undersigned will
also be required to withdraw as counsel for Khachartur Ghasabyan.
The interests of the cllients represented by the undersigned are protected by reason of an
agreement regarding outstanding discovery as follows: "The tolling of the responses to the
first sets of discovery propounded by my client Aldar Mini Storage, L.P. to your clients
Khachartur Glasabyan, Tigran Arutyunyun, THY Hayknarik, LLC, and THV Enterprises, in
the Aldar v. THY et.al. lawsuit, shall commence upon the filing of your motion to
withdraw as their attorney, (including the possible exception of non-withdraw as counsel
for Khachartur Glasabyan) and shall continue for a period of 45 days thereinafter."
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MC-052 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. state bar umber, and address): FOR COURT USE ONLY Ronald D. Dessy = (Bar # 96398) Fawn Kennedy Dessy SBN 90087 Dessy & Dessy, APC, 1301 L Street Bakersfield, CA 93301 TELEPHONE NO: (661) 322-3863 ___Faxwo: (661) 395-1024 HV Enterprises, a California corporation, THV Hayknarix, LLC, 2 California ATTORNEY FOR (Name) 1 ted Iealbite, ywand Ligcs uh Defendant: Name OF couRT:SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN strcet aooress 1415 Truxtun Avenue MAILING ADDRESS. Same as above city ano zip cone: Bakersfield 93301 erancu name: Metropolitan Division- Unlimited Civil CASE NAME: (CASE NUMBER Aldar Mini Storage, L.P.. vs THV Enterprises, a California corporation, et al., BCV-20-101265-SDS and Related Cross-Compiaint nearinc Dave: February 2, 2022 DECLARATION IN SUPPORT OF ATTORNEY'S. or H we 8:30am MOTION TO BE RELIEVED AS COUNSEL—CIVIL serosevenBernard C Barmann, Jr. pate action sien: Jume 1, 2020 sia. ore May 23, 2022 4. Attorney and Represented Party. Attorney (name): Ronald D. Dessy, Fawn Kennedy Dessy, and Dessy & Dessy, APC is presently counsel of record for (name of party): Triv Enterprises. a California corporation; THV Hayknarik. LLC, a California limited liability in the above-captioned action or proceeding. company; and ‘Tigran Arutunyan, Defendants/Cross-Defendants 2. Reasons for Motion. Attorney makes this motion to be relieved as counsel under Code of Civit Procedure section 284(2) instead of filing a consent under section 284(1) for the following reasons (describe): Continued on Attachment 2. 3. Service a. Attorney has (1) 2) personally served the client with copies of the motion papers filed with this declaration. A copy of the proof of service will be filed with the court at ieast 5 days before the hearing. (2) (1 served the client by mail at the client's last known address with copies of the motion papers served with this declaration. b. If the client has been served by mail at the client's last known address, attorney has a) confirmed within the past 30 days that the address is current (a)[_] by mail, return receipt requested. (b) £7} by telephone. (c) 2] by conversation, (a) by other means (specify): Statement of Information forms filed with California Secretary of State {Continued on reverse} Page 1 of 2 ronal Gomciol alta DECLARATION IN SUPPORT OF ATTORNEY'S Goce of Civ Procedure, § 284, MiC-O82 Rev. Jarry $, 2007] MOTION TO BE RELIEVED AS COUNSEL—CIVIL ve Sort £8 G09 LexisNexis® Automated Califorma Judicial Council FormsMC-052 CASE NAME: CASE NUMBER Aldar Mini Storage, L.P., vs THV Enterprises, a California corporation, et al., BCV-20-101265-SDS 3. b. (2) Co been unable to confirm that the address is current or fo locate a more current address for the client after making the following efforts: (a) [C7] maiting the motion papers to the client's fast known address, return receipt requested. (b) [-] calling the client's iast known telephone number or numbers. {c) C3 contacting persons familiar with the client (specify): (a) [7] conducting a search (describe): (e) [7] other (specify): c. Even if attorney has been unabie to serve the client with the moving papers, the court should grant attorney's motion to be relieved as counsel of record (explain): 4. The next hearing scheduled in this action or proceeding a. [_] isnot yet set b. EX] is set as follows (specify the date, time, and place): MSC on 4/19/22, at 1:30pm Dpt. 1, at KCSC, 1415 Truxun Ave., Bakersfield, Ca; FCMC on 5/2322, at 9:00am, Div. H at KCSC, 1215 Truxtun Ave., Bakersfield, Ca ¢. [_] concems (describe the subject matter of the hearing): (_] Continued on Attachment 4 5. The following additional hearings and other proceedings (including discovery matters) are presently scheduled in this case (for each, describe the date, time, place, and subject matter): Discovery responses due in about 45 days by THV Enterprises, a California corporation, THV Hayknarik, LLC, a California limited liability company, and Tigran Arutunyan. [J Continued on Attachment 5. 6. Trial in this action or proceeding a. [] is not yet set. b. is set as follows (specify the date, time, and place): May 23, 2022, at 9:00am, Div. H at KCSC, 1215 Truxtun Ave., Bakersfield, Ca 7. Other, Other matters that the court should consider in determining whether to grant this motion are the following (explain): i declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: January 4, 2022 Ronald D. Dessy {T¥PE OR PRINT NAME} (st URE OF DECLARANT) 8. Number of pages attached: 1 MC-O82 [Rew Jonsary 42007 DECLARATION IN SUPPORT OF ATTORNEY'S Page 2 0f2 MOTION TO BE RELIEVED AS COUNSEL—CIVIL LexisNexis® Automated California Judicial Council FormsAttachments Attachment 2 This Motion was filed only after the clients were given an opportunity to sign substitutions of attorney, and did not do so. Despite numerous efforts, the undersigned has been unable to establish any communication between Tigran Arutunyan and the undersigned since July of 2021. At the point of the last communication, Tigran Arutunyan and the undersigned had a difference of perspective on the manner in which the undersigned should handle certain details related to the case. Since Tigran Arutunyan has an interest in THV Enterprises, Inc. and HayKnarik, LLC, the undersigned must also withdraw from the representation of those parties. Unless the undersigned is able to obtain conflict waiver consent from Tigran Arutunyan to the undersigned’s continued representation of Khachartur Ghasabyan, the undersigned will also be required to withdraw as counsel for Khachartur Ghasabyan. The interests of the cllients represented by the undersigned are protected by reason of an agreement regarding outstanding discovery as follows: "The tolling of the responses to the first sets of discovery propounded by my client Aldar Mini Storage, L.P. to your clients Khachartur Glasabyan, Tigran Arutyunyun, THY Hayknarik, LLC, and THV Enterprises, in the Aldar v. THY et.al. lawsuit, shall commence upon the filing of your motion to withdraw as their attorney, (including the possible exception of non-withdraw as counsel for Khachartur Glasabyan) and shall continue for a period of 45 days thereinafter."