Preview
ARA JABAGCHOURIAN (SBN 205777)
araQarailaw.corn
LAW OFFICES OF ARA JABAGCHOURIAN, P.C.
1650 S. Amphlett Boulevard, Suite 216
San Mateo, CA 94402
Telephone: (650) 437-6840
Facsimile: (650) 403-0909
Attorneys for Defendants
Aria Sarbetand, and
Martha Sarbeland
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
10
KHALIL MSALAM, JULNAR MSALAM, CASE NO. 19CIV02602
12 JIMILAH MSALAM, GHASSAN
MSALAM through her G.A.L. Jimilah
13 Msalam, JAMIE MSALAM through his DECLARATION OF ARA
JABAGCHOURIAN IN SUPPORT OF
14
G.A.L. Jimilah Msalam, JONATHAN MOTION TO COMPEL DEPOSITIONS
MSALAM through his G.A.L. Jimilah
15 Msalam, ANDREW MSALAM through his Date: March 25, 2022
G.A.L. Jimilah Msalam Time: 9:00 a.m.
16 Judge: Honorable Robert D. Foiles
Plaintiffs, Dept: 21
17
18
19 ARIA SARBELAND, FREDDIE A.
ARELLANO, JR. MARTHA
20 SARBELAND, individually and in his
official capacity, and DOES 1-20
21
individually and in their official capacities.
22
Defendants.
23
24
25
26
27
28
Law Offices of DECLARATION OF ARA JABAGCHOURIAN IN SIJPPORT OF MOTION TO COMPEL
Ara DEPOSITIONS
Jabagcbourian,
P.C.
DECLARATION OF ARA JABAGCHOURIAN
2 I, Ara Jabagchourian, declare and affirm as follows:
1. I am the attorney for the defendant on the above captioned matter and am a
partner of the Law Offices of Ara Jabagchourian, P.C.. I make this declaration of
my own personal knowledge, and if called upon, I would competently testify
accurately thereto.
2. An informal discovery conference was held to compel the deposition of Andrew
Msalam on September 24, 2021. Plaintiffs'ounsel took the position that because
he was a minor (16.5 years old), his mother should testify in his place. The
10 parties agreed at the conference to take Andrew's deposition on the same day as
his parents.
12 3. Attached hereto as Exhibit A are true and conect portions of the certified
13 transcript of the deposition of Julnar Msalam taken November 4, 2021.
14 4. Attached hereto as Exhibit B are true and correct portions of the certified
15 transcript of the deposition of Khalil Msalam taken November 4, 2021.
16 5. I sought to meet and confer regarding getting Julnar and Khalil's respective
17 depositions back on calendar. Rather, Ms. Parmenter, attorney for Plaintiffs in
18 this action, stated that she produced both individuals, implying that the obligation
19 to produce them has been met. A true and correct email chain dated November 4,
20 2021 between myself and Ms. Parmenter is attached hereto as Exhibit C. An
21 informal discovery conference was held on this issue on January 4, 2022.
22
Istate the foregoing under penalty of perjury under the laws of the California and
3
24 attest that the foregoing is true and correct. Signed on January 12, 2022 in San Mateo,
25 California.
26
ARA BAGCHOURIAN
27
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Law OIBccs of DECLARATION OF ARA JABAGCHOURIAN IN SUPPORT OF MOTION TO COMPEL
Ara DEPOSITIONS
Jabagchonrtan,
P.C.
EXHIBIT A
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
---oOo---
KHALIL MSALAM, JULNAR MSALAM, CASE NO.
JIMILAH MSALAMy GHASSAN MSALAMf 19 CIV 02602
5 through his G.A.L. Jimilah Msalam,
JAIME MSALAM, through his G.A.L.
6 Jimilah Msalam, JONATHAN MSALAM,
through his G.A.L. Jimilah Msalam,
7 ANDREW MSALAM through his G.A.L.
Jimilah Msalam;
8
Plaintiffs,
CERTIFIED TRANSCRIPT
10
ARIA SARBELAND, FREDDIE A.
11 ARELLANO, JR., MARTHA SARBELAND,
individually and in his official
12 capacity, and DOES 1-20 individually
and in their official capacities,
13
Defendants.
15
16 VIDEOCONFERENCE DEPOSITION OF JULNAR MSALAM
17 THURSDAY, NOVEMBER 4, 2021
18
19 Stenographically Reported By:
20 LUCY CARRILLO GRUBBS~ CSR 467 66 WA CSR 53471 OR CSR
520 04 63 ~ RPR~ RMR CRR CCRR
21
22
UCCELLI & ASSOCIATES, INC.
23 1243 Mission Road
South San Francisco, CA 94080
24 www.UccelliAssociates.corn
E-mail: info8UccelliAssociates.corn
25 Tel: 650.952.0774 Fax: 650.952.8688
JULNAR MSALAM 11-04-2021
1 bigger?
2 Q. Sure.
3 A. I'm on my laptop, sorry.
4 Q. No problem.
Look at paragraph 20 there. I'l highlight it
6 for you, that sentence there. So that sentence that I
7 read, ma'm, is that an accurate statement?
8 A. Yes.
9 Q. Okay. Go to the next sentence of paragraph 20
10 reads, "Pursuant to the agreement, plaintiffs paid a
ll security deposit of $ 2500 and diligently paid their rent
12 each month to defendants in the amount of 82500."
13 Did I read that accurately?
14 A. I'm not sure about the deposit, I thought we
15 paid more for the deposit. But yes, the rent was wrote.
16 Q. Is that statement a true statement?
17 A. Yes.
18 Q. So your -- your testimony is that you -- you,
19 you -- you, your husband and your children -- I'l just
20 say you and your husband -- diligently paid the rent
21 each month to defendants in the amount of $ 2500, for the
22 eight years, is that true?
23 A. Not for the eight years, because I said, you
24 know, we have housing assistant. So we used to pay, you
25 know, like a portion of the housing, they have to pay
650.952.0774 Uccelli S Associates, Inc. 650.952.8688
JULNAR MSALAM 11-04-2021
1 that portion.
2 Q. Got it. How much did that -- did the
3 government
ATTORNEY PARMENTER: I want to take a break,
5 please. Can I take a break? I need to take a break.
ATTORNEY JABAGCHOURIAN: Sure. Let me finish
7 this line of questioning.
ATTORNEY PARMENTER: I asked for a break before
9 you asked your question.
10 ATTORNEY JABAGCHOURIAN: That's fine, I'm not
11 going off the record yet, ma'm.
12 ATTORNEY PARMENTER: We are going off the
13 record because I would like to take a break. So I need
14 to take a break and
15 ATTORNEY JABAGCHOURIAN: You can go ahead and
16 take a break, ma'm. You go ahead and take a break, but
17 we'e not going to have you coach your witness.
18 ATTORNEY PARMENTER: I'm not coaching anyone
19 and I have a right to take a break.
20 ATTORNEY JABAGCHOURIAN: When I'm done with my
21 line of questioning, ma'm.
22 ATTORNEY PARMENTER: I'm not going to go
23 through a line of questioning, as you indicated earlier.
24 ATTORNEY JABAGCHOURIAN: Yeah.
25 ATTORNEY PARMENTER: If the question was not
650.952.0774 Uccelli & Associates, Inc. 650.952.8688
JULNAR MSALAM 11-04-2021
1 asked, I can take a break. I need to use the restroom.
ATTORNEY JABAGCHOURIAN: You can go ahead and
3 leave, ma'm. Ms. -- Ms. Msalam--
ATTORNEY PARMENTER: You will not proceed if
5 you are acting this way. I understand
6 BY ATTORNEY JABAGCHOURIAN:
7 Q. Ms. Msalam, do you need to take a break?
8 Ms. Msalam, do you need to take a break?
9 A. Yes.
10 ATTORNEY PARMENTER: You do not
BY ATTORNEY JABAGCHOURIAN:
12 Q. Ms. Msalam, did you need to take a break?
13 A. Yes.
ATTORNEY JABAGCHOURIAN: Let's go ahead and
15 take a break so your attorney can coach you during the
16 time.
17 Go ahead, we'e off the record.
18 ATTORNEY PARMENTER: Okay, just a minute
19 please. That is very inappropriate
20 ATTORNEY JABAGCHOURIAN: Off the record.
21 ATTORNEY PARMENTER: -- what you are doing
22 right now.
23 ATTORNEY JABAGCHOURIAN: Ma'm, you'e
24 interrupting my deposition, we haven't even gone an
25 hour.
650.952.0774 Uccelli S Associates, Inc. 650.952.8688
JULNAR MSALAM 11-04-2021
ATTORNEY PARMENTER: You'e
ATTORNEY JABAGCHOURIAN: You'e interrupting my
3 question because your client right now is showing
4 that
(Cross talk between attorneys.)
ATTORNEY PARMENTER: We are going to terminate
7 this deposition.
ATTORNEY JABAGCHOURIAN: You lost all
9 credibility here.
10 ATTORNEY PARMENTER: It's an inappropriate
11 pattern.
12 ATTORNEY JABAGCHOURIAN: There's lies in the
13 complaint that you filed in court.
ATTORNEY PARMENTER: Just a minute.
15 ATTORNEY JABAGCHOURIAN: That are already shown
16 to be lies, ma'm. So you'e now trying to rehabilitate
17 your client during the break, it's obvious that
18 ATTORNEY PARMENTER: Are you out of your
19 ATTORNEY JABAGCHOURIAN: Go ahead and do that,
20 ma'm.
21 ATTORNEY PARMENTER: We are now going
22 ATTORNEY JABAGCHOURIAN: Go ahead and do that.
23 ATTORNEY PARMENTER: You'e
ATTORNEY JABAGCHOURIAN: You'e going to be
25 held accountable for malicious prosecution with
650.952.0774 Uccelli S Associates, Inc. 650.952.8688
JULNAR MSALAM 11-04-2021
CERTIFIED SHORTHAND REPORTER'S CERTIFICATE
I LUCY CARRILLO GRUBBS~ CRR~ RPR~ RMR CSR
4 ¹6766, hereby certify that I am a Certified Shorthand
5 Reporter in and for the State of California.
I hereby certify that the witness in the
7 foregoing deposition, JULNAR MSALAM, was by me duly
8 sworn to testify the truth, the whole truth, and nothing
9 but the truth; that said deposition was taken at the
10 time and place therein set forth; and was taken down by
11 me in st.enotype and thereafter transcribed into
12 typewriting by computer; and that the deposition is a
13 true record of the testimony given by the witness.
I further certify that I am neither counsel
15 for, nor related in any way to any party to said action,
16 nor otherwise interested in the result or outcome
17 thereof.
18 Dated the 10th of November, 2021
19
20
21
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23
24 LUCY CARRILLO-GRUBBS, CSR No. 6766
25
650.952.0774 Uccelli a Associates, Inc. 650.952.8688 50
EXHIBIT B
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
---oOo---
4 KHAL I L MSALAM ~ JULNAR MSALAM / CASE NO.
JIMILAH MSALAM, GHASSAN MSALAM,
5 through his G.A.L. Jimilah 19 CIV 02602
Msalam, JAIME MSALAM through
6 his G.A.L. Jimilah Msalam,
Jonathan Msalam through his
7 G.A.L. Jimilah Msalam,
ANDREW MSALAM through his
8 G.A.L. Jimilah Msalam,
CERTIFIED TRANSCRIPT
Plaintiffs,
10 V.
11 ARIA SARBELAND~ FREDDIE A
ARELLANO, JR., MARTHA
12 SARBELAND, individually and in
his official capacity, and DOES
13 1-20 individually and in their
official capacities,
14
Defendants.
15
16
17 VIDEOCONFERENCE DEPOSITION OF KHALIL MSALAM
THURSDAY, NOVEMBER 4, 2021
19
20 Stenographically Reported By:
21 LUCY CARRILLO-GRUBBS, CSR ¹6766, WA CSR ¹3471, OR CSR
¹20-0463, RPR, RMR, CRR, CCRR
22
UCCELLI & ASSOCIATES, INC.
23 1243 Mission Road
South San Francisco, CA 94080
24 www.UccelliAssociates.corn
E-mail: infoaUccelliAssociates.corn
25 Tel: 650.952.0774 Fax: 650.952.8688
KHALIL NSALAN 11-04-2021
ATTORNEY PARNENTER: I need to take a break
2 and
ATTORNEY JABAGCHOURIAN: Take your break.
ATTORNEY PARNENTER: We will -- Khalil, we will
5 take a break now.
ATTORNEY JABAGCHOURIAN: Take your break.
7 THE WITNESS: Yes.
COURT REPORTER: We'e off the record.
(Recess taken at 2:20 p.m. and proceedings
10 recommenced at 2:29 p.m.)
BY ATTORNEY JABAGCHOURIAN:
12 Q. Sir, did you ever tell the housing authority
13 that there was
ATTORNEY PARMENTER: My client needed to make
15 some clarification. Nake your clarifications, Khalil.
16 BY ATTORNEY JABAGCHOURIAN:
17 Q. Just so I got it, sir, you want to make some
18 clarifications after speaking with your attorney during
19 the break?
20 ATTORNEY PARMENTER: Did I say that, Counsel?
21 ATTORNEY JABAGCHOURIAN: Well, that's what I'm
22 asking.
23 Q. Did you seek to make any clarifications after
24 the break, after speaking with your attorney?
25 A. I want to make a clarification, yes.
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KHALIL NSALAN 11-04-2021
1 Q. Go ahead.
2 A. On the cracks that were on the kitchen window,
3 Andrew's room and Johnny's room, the family room and the
4 other room by the kitchen. They'e all leaking water
5 and air. Cold air was coming from it.
6 Q. And just so I got it, so I understand, you
7 indicated before the break that you didn't recall, what
8 did you do to go about recalling those specific windows?
9 A. I was looking at memory.
10 Q. What memory were you looking at?
11 A. I have memories.
12 Q. So just based on your memory?
13 A. No. Remember memory.
14 Q. Got it.
15 Any other issues? Because there was a lot of I
16 don't recalls. Any other things you want to correct?
17 A. No, this is it.
18 ATTORNEY PARMENTER: Khalil, we did have two
19 other things you needed to clarify.
20 THE WITNESS: Oh, on the 150, I can't recall on
21 that day how many time that person came into the house.
22 ATTORNEY JABAGCHOURIAN: Got it.
23 ATTORNEY PARNENTER: And there's another
24 clarification with regards to the housing authority.
25 THE WITNESS: The housing authority kept asking
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KHALIL MSALAM 11-04-2021
We have now exceeded the two-hour period that
2 you noticed and we also have -- I don't want to cut you
3 short, I want you to take your deposition, so,
therefore, I would like to know what -- how much more
5 time you need for this, and what we should do with
6 regards to the remaining deposition.
ATTORNEY JABAGCHOURIAN: Sure.
ATTORNEY PARMENTER: Thank you.
ATTORNEY JABAGCHOURIAN: I probably have about
10 another 45 minutes with this witness. I never indicated
11 to the Court that I was going to limit your other two
12 clients to two hours. I was going to limit Andrew to
13 two hours.
ATTORNEY PARMENTER: Well, the notice I
15 received, Counsel, stated a two-hour period and you
16 noticed them all for the same date.
17 ATTORNEY JABAGCHOURIAN: Correct.
18 ATTORNEY PARMENTER: This one was supposed
19 to -- we were supposed to take a break between 1:30 and
20 3:30. It's now almost, you know, 3:44, and we were
21 supposed to take a one-hour break.
22 So I don't want to rush you, I don't want to
23 prevent you from asking your questions, but I would like
24 to know what the proceed -- what you'e going to do, if
25 you don't mind. Thanks.
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KHALIL MSALAM 11-04-2021
ATTORNEY JABAGCHOURIAN: I intend to continue
2 to depose your witness right now, your client right now
3 probably for about another 45 minutes. It's up to you
4 whether or not you'e going to put your client up and
5 then we have to go back and figure out when we'e going
6 to take your other witnesses, your other clients'
deposition.
THE WITNESS: He
ATTORNEY PARMENTER: That was separate. So
10 you'e going to terminate this one in around 45 minutes,
11 you believe?
12 ATTORNEY JABAGCHOURIAN: We'l see. Depends on
13 what kind of answers I get.
14 ATTORNEY PARMENTER: That's fine, give or take.
15 And then you want to take Andrew's deposition?
16 ATTORNEY JABAGCHOURIAN: If he's available.
17 ATTORNEY PARMENTER: What time should we ask
18 him to come, that's what I need to make sure.
19 THE WITNESS: Andrew's not here, he left.
20 ATTORNEY PARMENTER: Okay.
21 THE WITNESS: His appointment was at 10:30 in
22 the morning.
23 ATTORNEY JABAGCHOURIAN: His appointment, what
24 appointment was 10:30?
25 ATTORNEY PARMENTER: Just a minute, I don'
650.952.0774 Uccelli a Associates, Inc. 650.952.8688 126
KHALIL MSALAM 11-04-2021
1 want you to answer -- ask any questions
What -- so you'e going to terminate this in
3 around one hour.
4 ATTORNEY JABAGCHOURIAN: Approximately.
ATTORNEY PARMENTER: Okay, approximately,
6 that's fine.
Okay. So I don't know if Andrew's going to be
8 available at that time.
But we will proceed then. We should take a
10 break also between these depositions.
ATTORNEY JABAGCHOURIAN: Okay.
12 ATTORNEY PARMENTER: Thank you.
13 BY ATTORNEY JABAGCHOURIAN:
14 Q. There's another photograph here, the one after
15 the couch, what's -- what's depicted in this photograph?
16 This is again Exhibit 4. It looks like some wood board
17 with something red to the left and maybe a window to the
18 right. What is this?
19 A. I can't -- to be honest with you, maybe that'
20 one of the windows.
21 Q. Okay.
22 And why was this photograph taken?
23 A. Because all -- you see the gaps right there on
24 top, that's the gaps was all the cold air was coming
25 from it in the winter.
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KHALIL MSALAM 11-04-2021
1 Q. And you felt that she was a bad landlord,
2 correct?
3 A. Very bad landlord. Her dad, a wonderful man.
4 Q. Do you know if your wife held the same opinion?
5 A. I don't know. That's my opinion. I'm not
6 going to back them, but, you know.
7 Q. Did you ever speak with your wife about what
8 kind of landlord Martha was?
9 A. No.
10 ATTORNEY JABAGCHOURIAN: I'm going over my
11 notes, Counsel. Is Andrew going to be available this
12 afternoon or no?
13 THE WITNESS: No, sir, Andrew left already to
14 work.
15 ATTORNEY JABAGCHOURIAN: Okay.
16 Q. What time does Andrew start work?
17 A. Normally
18 ATTORNEY PARMENTER: Counsel, I believe you
19 asked Counsel.
20 BY ATTORNEY JABAGCHOURIAN:
21 Q. 4:00 p.m., sir?
22 A. Yes.
23 Q. Got it.
Was there ever a social worker or a case
25 manager that would come to your home between 2011 and
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KHALIL MSALAM 11-04-2021
CERTIFIED SHORTHAND REPORTER'S CERTIFICATE
I, LUCY CARRILLO-GRUBBS, CRR, RPR, RMR, CSR
¹6766, hereby certify that I am a Certified Shorthand
5 Reporter in and for the State of California.
I hereby certify that the witness in the
7 foregoing deposit.ion, KHALIL MSALAM, was by me duly
8 sworn to testify the truth, the whole truth, and nothing
9 but the truth; that said deposition was taken at the
10 time and place therein set forth; and was taken down by
11 me in stenotype and thereafter transcribed into
12 typewriting by computer; and that the deposition is a
13 true record of the testimony given by the witness.
I further certify that I am neither counsel
15 for, nor related in any way to any party to said action,
16 nor otherwise interested in the result or outcome
17 thereof.
18 Dated the 16th of November, 2021
19
20
~
21
22
23
4~34-~
LUCY CARRILLO-GRUBBS, CSR No. 6766
25
650.952.0774 Uccelli a Associates, Inc. 650.952.8688 172
EXHIBIT C
Ara Jabagchourian
From: Ara Jabagchourian
Sent: Thursday, November 4, 2021 8:55 PM
To: L.M.Parmenter
Subject: Re: error Msalam v. Sarbeland l
Deponent Andrew Msalam
While he was no longer available for deposition at 3:45 when he went to work for his 4 pm shift. How was going to
I
take a 2 hour deposition when he had left for work 15 minutes after his deposition was to start?
When is heavailable for deposition?
Sent from my iPhone
On Nov 4, 2021, at 8:50 PM, L.M.Parmenter &Imparmenter@lawpar.corn& wrote:
That is completely false.
Julnar Msalam, Khalil Msalam and Andrew Msalam were all produced today,
November 4, 2021, as per the notices of deposition of your clients. My clients
and Iwent through great lengths to find one (1) deposition date as per your
specific demand for all of three (3) depositions to take place on one (1) date.
Iasked you several times to take the deposition on separate dates, but you
angrily refused.
Minor child Andrew Msalam normally works on this date and time and scheduled time to
be available as per your notice and demand that his deposition be taken last at 3:30
p.m. You noticed Andrew Msalam's deposition for 3:30 p.m. and you continued to take
the deposition of Khalil Msalam until the time frame of 5 p.m.
~TT~ Ligia M. Parmenter, Esq.
501 '8'treet, Ste. 200
Parmenter Law Offices San Rafae I, CA 94901
Tel/Fax: (415) 738-7901
Attorneys at 1.aw
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On Thursday, November 4, 2021, 08:24:29 PM PDT, Ara Jabagchourian &ara@arajlaw.corn& wrote:
No. He was not produced. In fact,he was noticed for a 3:30 deposition and he had leff for his job shift at
Roundtable at 4 pm, Quit making facts up. Because you write it does not make it true.
Sent from my iPhone
On Nov 4, 2021, at 8:08 PM, L.M.Parmenter &ImparmenterOlawpar.corn& wrote:
My apologies, I neglected to write the word "lvir."prior to your last name.
--- Forwarded Message---
From: L.M.Parmenter &Imparmenter@lawpar.corn&
To: Ara Jabagchourian &araOarajlaw.corn&
Cc: Manny Juarez &baylawt@yahoo.corn&; Cynthia Anaya &cynthiaoaerlegal.corn&;
Anthony E. Rodriguez &anthony@aerlegal.corn&
Sent: Thursday, November 4, 2021, 08:05:54 PM PDT
Subject: Msalam v. Sarbeland l
Deponent Andrew Msalam
Dear Jabagchorian:
This shall confirm that pursuant to the deposition notice of your clients',
minor child Andrew Msalam, was produced for his deposition which was
noticed for November 4, 2021 at 3:30 p.m. That deposition did not take
place due to your need to continue to take the deposition of Mr. Khalil
Msalam unit 5 p.m.
Very truly yours,
Ligia M. Parmenter
Ligia M. Parrnentar, Esq.
Preview
ARA JABAGCHOURIAN (SBN 205777) araQarailaw.corn LAW OFFICES OF ARA JABAGCHOURIAN, P.C. 1650 S. Amphlett Boulevard, Suite 216 San Mateo, CA 94402 Telephone: (650) 437-6840 Facsimile: (650) 403-0909 Attorneys for Defendants Aria Sarbetand, and Martha Sarbeland SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO 10 KHALIL MSALAM, JULNAR MSALAM, CASE NO. 19CIV02602 12 JIMILAH MSALAM, GHASSAN MSALAM through her G.A.L. Jimilah 13 Msalam, JAMIE MSALAM through his DECLARATION OF ARA JABAGCHOURIAN IN SUPPORT OF 14 G.A.L. Jimilah Msalam, JONATHAN MOTION TO COMPEL DEPOSITIONS MSALAM through his G.A.L. Jimilah 15 Msalam, ANDREW MSALAM through his Date: March 25, 2022 G.A.L. Jimilah Msalam Time: 9:00 a.m. 16 Judge: Honorable Robert D. Foiles Plaintiffs, Dept: 21 17 18 19 ARIA SARBELAND, FREDDIE A. ARELLANO, JR. MARTHA 20 SARBELAND, individually and in his official capacity, and DOES 1-20 21 individually and in their official capacities. 22 Defendants. 23 24 25 26 27 28 Law Offices of DECLARATION OF ARA JABAGCHOURIAN IN SIJPPORT OF MOTION TO COMPEL Ara DEPOSITIONS Jabagcbourian, P.C. DECLARATION OF ARA JABAGCHOURIAN 2 I, Ara Jabagchourian, declare and affirm as follows: 1. I am the attorney for the defendant on the above captioned matter and am a partner of the Law Offices of Ara Jabagchourian, P.C.. I make this declaration of my own personal knowledge, and if called upon, I would competently testify accurately thereto. 2. An informal discovery conference was held to compel the deposition of Andrew Msalam on September 24, 2021. Plaintiffs'ounsel took the position that because he was a minor (16.5 years old), his mother should testify in his place. The 10 parties agreed at the conference to take Andrew's deposition on the same day as his parents. 12 3. Attached hereto as Exhibit A are true and conect portions of the certified 13 transcript of the deposition of Julnar Msalam taken November 4, 2021. 14 4. Attached hereto as Exhibit B are true and correct portions of the certified 15 transcript of the deposition of Khalil Msalam taken November 4, 2021. 16 5. I sought to meet and confer regarding getting Julnar and Khalil's respective 17 depositions back on calendar. Rather, Ms. Parmenter, attorney for Plaintiffs in 18 this action, stated that she produced both individuals, implying that the obligation 19 to produce them has been met. A true and correct email chain dated November 4, 20 2021 between myself and Ms. Parmenter is attached hereto as Exhibit C. An 21 informal discovery conference was held on this issue on January 4, 2022. 22 Istate the foregoing under penalty of perjury under the laws of the California and 3 24 attest that the foregoing is true and correct. Signed on January 12, 2022 in San Mateo, 25 California. 26 ARA BAGCHOURIAN 27 28 Law OIBccs of DECLARATION OF ARA JABAGCHOURIAN IN SUPPORT OF MOTION TO COMPEL Ara DEPOSITIONS Jabagchonrtan, P.C. EXHIBIT A 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO ---oOo--- KHALIL MSALAM, JULNAR MSALAM, CASE NO. JIMILAH MSALAMy GHASSAN MSALAMf 19 CIV 02602 5 through his G.A.L. Jimilah Msalam, JAIME MSALAM, through his G.A.L. 6 Jimilah Msalam, JONATHAN MSALAM, through his G.A.L. Jimilah Msalam, 7 ANDREW MSALAM through his G.A.L. Jimilah Msalam; 8 Plaintiffs, CERTIFIED TRANSCRIPT 10 ARIA SARBELAND, FREDDIE A. 11 ARELLANO, JR., MARTHA SARBELAND, individually and in his official 12 capacity, and DOES 1-20 individually and in their official capacities, 13 Defendants. 15 16 VIDEOCONFERENCE DEPOSITION OF JULNAR MSALAM 17 THURSDAY, NOVEMBER 4, 2021 18 19 Stenographically Reported By: 20 LUCY CARRILLO GRUBBS~ CSR 467 66 WA CSR 53471 OR CSR 520 04 63 ~ RPR~ RMR CRR CCRR 21 22 UCCELLI & ASSOCIATES, INC. 23 1243 Mission Road South San Francisco, CA 94080 24 www.UccelliAssociates.corn E-mail: info8UccelliAssociates.corn 25 Tel: 650.952.0774 Fax: 650.952.8688 JULNAR MSALAM 11-04-2021 1 bigger? 2 Q. Sure. 3 A. I'm on my laptop, sorry. 4 Q. No problem. Look at paragraph 20 there. I'l highlight it 6 for you, that sentence there. So that sentence that I 7 read, ma'm, is that an accurate statement? 8 A. Yes. 9 Q. Okay. Go to the next sentence of paragraph 20 10 reads, "Pursuant to the agreement, plaintiffs paid a ll security deposit of $ 2500 and diligently paid their rent 12 each month to defendants in the amount of 82500." 13 Did I read that accurately? 14 A. I'm not sure about the deposit, I thought we 15 paid more for the deposit. But yes, the rent was wrote. 16 Q. Is that statement a true statement? 17 A. Yes. 18 Q. So your -- your testimony is that you -- you, 19 you -- you, your husband and your children -- I'l just 20 say you and your husband -- diligently paid the rent 21 each month to defendants in the amount of $ 2500, for the 22 eight years, is that true? 23 A. Not for the eight years, because I said, you 24 know, we have housing assistant. So we used to pay, you 25 know, like a portion of the housing, they have to pay 650.952.0774 Uccelli S Associates, Inc. 650.952.8688 JULNAR MSALAM 11-04-2021 1 that portion. 2 Q. Got it. How much did that -- did the 3 government ATTORNEY PARMENTER: I want to take a break, 5 please. Can I take a break? I need to take a break. ATTORNEY JABAGCHOURIAN: Sure. Let me finish 7 this line of questioning. ATTORNEY PARMENTER: I asked for a break before 9 you asked your question. 10 ATTORNEY JABAGCHOURIAN: That's fine, I'm not 11 going off the record yet, ma'm. 12 ATTORNEY PARMENTER: We are going off the 13 record because I would like to take a break. So I need 14 to take a break and 15 ATTORNEY JABAGCHOURIAN: You can go ahead and 16 take a break, ma'm. You go ahead and take a break, but 17 we'e not going to have you coach your witness. 18 ATTORNEY PARMENTER: I'm not coaching anyone 19 and I have a right to take a break. 20 ATTORNEY JABAGCHOURIAN: When I'm done with my 21 line of questioning, ma'm. 22 ATTORNEY PARMENTER: I'm not going to go 23 through a line of questioning, as you indicated earlier. 24 ATTORNEY JABAGCHOURIAN: Yeah. 25 ATTORNEY PARMENTER: If the question was not 650.952.0774 Uccelli & Associates, Inc. 650.952.8688 JULNAR MSALAM 11-04-2021 1 asked, I can take a break. I need to use the restroom. ATTORNEY JABAGCHOURIAN: You can go ahead and 3 leave, ma'm. Ms. -- Ms. Msalam-- ATTORNEY PARMENTER: You will not proceed if 5 you are acting this way. I understand 6 BY ATTORNEY JABAGCHOURIAN: 7 Q. Ms. Msalam, do you need to take a break? 8 Ms. Msalam, do you need to take a break? 9 A. Yes. 10 ATTORNEY PARMENTER: You do not BY ATTORNEY JABAGCHOURIAN: 12 Q. Ms. Msalam, did you need to take a break? 13 A. Yes. ATTORNEY JABAGCHOURIAN: Let's go ahead and 15 take a break so your attorney can coach you during the 16 time. 17 Go ahead, we'e off the record. 18 ATTORNEY PARMENTER: Okay, just a minute 19 please. That is very inappropriate 20 ATTORNEY JABAGCHOURIAN: Off the record. 21 ATTORNEY PARMENTER: -- what you are doing 22 right now. 23 ATTORNEY JABAGCHOURIAN: Ma'm, you'e 24 interrupting my deposition, we haven't even gone an 25 hour. 650.952.0774 Uccelli S Associates, Inc. 650.952.8688 JULNAR MSALAM 11-04-2021 ATTORNEY PARMENTER: You'e ATTORNEY JABAGCHOURIAN: You'e interrupting my 3 question because your client right now is showing 4 that (Cross talk between attorneys.) ATTORNEY PARMENTER: We are going to terminate 7 this deposition. ATTORNEY JABAGCHOURIAN: You lost all 9 credibility here. 10 ATTORNEY PARMENTER: It's an inappropriate 11 pattern. 12 ATTORNEY JABAGCHOURIAN: There's lies in the 13 complaint that you filed in court. ATTORNEY PARMENTER: Just a minute. 15 ATTORNEY JABAGCHOURIAN: That are already shown 16 to be lies, ma'm. So you'e now trying to rehabilitate 17 your client during the break, it's obvious that 18 ATTORNEY PARMENTER: Are you out of your 19 ATTORNEY JABAGCHOURIAN: Go ahead and do that, 20 ma'm. 21 ATTORNEY PARMENTER: We are now going 22 ATTORNEY JABAGCHOURIAN: Go ahead and do that. 23 ATTORNEY PARMENTER: You'e ATTORNEY JABAGCHOURIAN: You'e going to be 25 held accountable for malicious prosecution with 650.952.0774 Uccelli S Associates, Inc. 650.952.8688 JULNAR MSALAM 11-04-2021 CERTIFIED SHORTHAND REPORTER'S CERTIFICATE I LUCY CARRILLO GRUBBS~ CRR~ RPR~ RMR CSR 4 ¹6766, hereby certify that I am a Certified Shorthand 5 Reporter in and for the State of California. I hereby certify that the witness in the 7 foregoing deposition, JULNAR MSALAM, was by me duly 8 sworn to testify the truth, the whole truth, and nothing 9 but the truth; that said deposition was taken at the 10 time and place therein set forth; and was taken down by 11 me in st.enotype and thereafter transcribed into 12 typewriting by computer; and that the deposition is a 13 true record of the testimony given by the witness. I further certify that I am neither counsel 15 for, nor related in any way to any party to said action, 16 nor otherwise interested in the result or outcome 17 thereof. 18 Dated the 10th of November, 2021 19 20 21 22 23 24 LUCY CARRILLO-GRUBBS, CSR No. 6766 25 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 50 EXHIBIT B 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO ---oOo--- 4 KHAL I L MSALAM ~ JULNAR MSALAM / CASE NO. JIMILAH MSALAM, GHASSAN MSALAM, 5 through his G.A.L. Jimilah 19 CIV 02602 Msalam, JAIME MSALAM through 6 his G.A.L. Jimilah Msalam, Jonathan Msalam through his 7 G.A.L. Jimilah Msalam, ANDREW MSALAM through his 8 G.A.L. Jimilah Msalam, CERTIFIED TRANSCRIPT Plaintiffs, 10 V. 11 ARIA SARBELAND~ FREDDIE A ARELLANO, JR., MARTHA 12 SARBELAND, individually and in his official capacity, and DOES 13 1-20 individually and in their official capacities, 14 Defendants. 15 16 17 VIDEOCONFERENCE DEPOSITION OF KHALIL MSALAM THURSDAY, NOVEMBER 4, 2021 19 20 Stenographically Reported By: 21 LUCY CARRILLO-GRUBBS, CSR ¹6766, WA CSR ¹3471, OR CSR ¹20-0463, RPR, RMR, CRR, CCRR 22 UCCELLI & ASSOCIATES, INC. 23 1243 Mission Road South San Francisco, CA 94080 24 www.UccelliAssociates.corn E-mail: infoaUccelliAssociates.corn 25 Tel: 650.952.0774 Fax: 650.952.8688 KHALIL NSALAN 11-04-2021 ATTORNEY PARNENTER: I need to take a break 2 and ATTORNEY JABAGCHOURIAN: Take your break. ATTORNEY PARNENTER: We will -- Khalil, we will 5 take a break now. ATTORNEY JABAGCHOURIAN: Take your break. 7 THE WITNESS: Yes. COURT REPORTER: We'e off the record. (Recess taken at 2:20 p.m. and proceedings 10 recommenced at 2:29 p.m.) BY ATTORNEY JABAGCHOURIAN: 12 Q. Sir, did you ever tell the housing authority 13 that there was ATTORNEY PARMENTER: My client needed to make 15 some clarification. Nake your clarifications, Khalil. 16 BY ATTORNEY JABAGCHOURIAN: 17 Q. Just so I got it, sir, you want to make some 18 clarifications after speaking with your attorney during 19 the break? 20 ATTORNEY PARMENTER: Did I say that, Counsel? 21 ATTORNEY JABAGCHOURIAN: Well, that's what I'm 22 asking. 23 Q. Did you seek to make any clarifications after 24 the break, after speaking with your attorney? 25 A. I want to make a clarification, yes. 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 58 KHALIL NSALAN 11-04-2021 1 Q. Go ahead. 2 A. On the cracks that were on the kitchen window, 3 Andrew's room and Johnny's room, the family room and the 4 other room by the kitchen. They'e all leaking water 5 and air. Cold air was coming from it. 6 Q. And just so I got it, so I understand, you 7 indicated before the break that you didn't recall, what 8 did you do to go about recalling those specific windows? 9 A. I was looking at memory. 10 Q. What memory were you looking at? 11 A. I have memories. 12 Q. So just based on your memory? 13 A. No. Remember memory. 14 Q. Got it. 15 Any other issues? Because there was a lot of I 16 don't recalls. Any other things you want to correct? 17 A. No, this is it. 18 ATTORNEY PARMENTER: Khalil, we did have two 19 other things you needed to clarify. 20 THE WITNESS: Oh, on the 150, I can't recall on 21 that day how many time that person came into the house. 22 ATTORNEY JABAGCHOURIAN: Got it. 23 ATTORNEY PARNENTER: And there's another 24 clarification with regards to the housing authority. 25 THE WITNESS: The housing authority kept asking 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 59 KHALIL MSALAM 11-04-2021 We have now exceeded the two-hour period that 2 you noticed and we also have -- I don't want to cut you 3 short, I want you to take your deposition, so, therefore, I would like to know what -- how much more 5 time you need for this, and what we should do with 6 regards to the remaining deposition. ATTORNEY JABAGCHOURIAN: Sure. ATTORNEY PARMENTER: Thank you. ATTORNEY JABAGCHOURIAN: I probably have about 10 another 45 minutes with this witness. I never indicated 11 to the Court that I was going to limit your other two 12 clients to two hours. I was going to limit Andrew to 13 two hours. ATTORNEY PARMENTER: Well, the notice I 15 received, Counsel, stated a two-hour period and you 16 noticed them all for the same date. 17 ATTORNEY JABAGCHOURIAN: Correct. 18 ATTORNEY PARMENTER: This one was supposed 19 to -- we were supposed to take a break between 1:30 and 20 3:30. It's now almost, you know, 3:44, and we were 21 supposed to take a one-hour break. 22 So I don't want to rush you, I don't want to 23 prevent you from asking your questions, but I would like 24 to know what the proceed -- what you'e going to do, if 25 you don't mind. Thanks. 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 125 KHALIL MSALAM 11-04-2021 ATTORNEY JABAGCHOURIAN: I intend to continue 2 to depose your witness right now, your client right now 3 probably for about another 45 minutes. It's up to you 4 whether or not you'e going to put your client up and 5 then we have to go back and figure out when we'e going 6 to take your other witnesses, your other clients' deposition. THE WITNESS: He ATTORNEY PARMENTER: That was separate. So 10 you'e going to terminate this one in around 45 minutes, 11 you believe? 12 ATTORNEY JABAGCHOURIAN: We'l see. Depends on 13 what kind of answers I get. 14 ATTORNEY PARMENTER: That's fine, give or take. 15 And then you want to take Andrew's deposition? 16 ATTORNEY JABAGCHOURIAN: If he's available. 17 ATTORNEY PARMENTER: What time should we ask 18 him to come, that's what I need to make sure. 19 THE WITNESS: Andrew's not here, he left. 20 ATTORNEY PARMENTER: Okay. 21 THE WITNESS: His appointment was at 10:30 in 22 the morning. 23 ATTORNEY JABAGCHOURIAN: His appointment, what 24 appointment was 10:30? 25 ATTORNEY PARMENTER: Just a minute, I don' 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 126 KHALIL MSALAM 11-04-2021 1 want you to answer -- ask any questions What -- so you'e going to terminate this in 3 around one hour. 4 ATTORNEY JABAGCHOURIAN: Approximately. ATTORNEY PARMENTER: Okay, approximately, 6 that's fine. Okay. So I don't know if Andrew's going to be 8 available at that time. But we will proceed then. We should take a 10 break also between these depositions. ATTORNEY JABAGCHOURIAN: Okay. 12 ATTORNEY PARMENTER: Thank you. 13 BY ATTORNEY JABAGCHOURIAN: 14 Q. There's another photograph here, the one after 15 the couch, what's -- what's depicted in this photograph? 16 This is again Exhibit 4. It looks like some wood board 17 with something red to the left and maybe a window to the 18 right. What is this? 19 A. I can't -- to be honest with you, maybe that' 20 one of the windows. 21 Q. Okay. 22 And why was this photograph taken? 23 A. Because all -- you see the gaps right there on 24 top, that's the gaps was all the cold air was coming 25 from it in the winter. 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 127 KHALIL MSALAM 11-04-2021 1 Q. And you felt that she was a bad landlord, 2 correct? 3 A. Very bad landlord. Her dad, a wonderful man. 4 Q. Do you know if your wife held the same opinion? 5 A. I don't know. That's my opinion. I'm not 6 going to back them, but, you know. 7 Q. Did you ever speak with your wife about what 8 kind of landlord Martha was? 9 A. No. 10 ATTORNEY JABAGCHOURIAN: I'm going over my 11 notes, Counsel. Is Andrew going to be available this 12 afternoon or no? 13 THE WITNESS: No, sir, Andrew left already to 14 work. 15 ATTORNEY JABAGCHOURIAN: Okay. 16 Q. What time does Andrew start work? 17 A. Normally 18 ATTORNEY PARMENTER: Counsel, I believe you 19 asked Counsel. 20 BY ATTORNEY JABAGCHOURIAN: 21 Q. 4:00 p.m., sir? 22 A. Yes. 23 Q. Got it. Was there ever a social worker or a case 25 manager that would come to your home between 2011 and 650.952.0774 Uccelli S Associates, Inc. 650.952.8688 156 KHALIL MSALAM 11-04-2021 CERTIFIED SHORTHAND REPORTER'S CERTIFICATE I, LUCY CARRILLO-GRUBBS, CRR, RPR, RMR, CSR ¹6766, hereby certify that I am a Certified Shorthand 5 Reporter in and for the State of California. I hereby certify that the witness in the 7 foregoing deposit.ion, KHALIL MSALAM, was by me duly 8 sworn to testify the truth, the whole truth, and nothing 9 but the truth; that said deposition was taken at the 10 time and place therein set forth; and was taken down by 11 me in stenotype and thereafter transcribed into 12 typewriting by computer; and that the deposition is a 13 true record of the testimony given by the witness. I further certify that I am neither counsel 15 for, nor related in any way to any party to said action, 16 nor otherwise interested in the result or outcome 17 thereof. 18 Dated the 16th of November, 2021 19 20 ~ 21 22 23 4~34-~ LUCY CARRILLO-GRUBBS, CSR No. 6766 25 650.952.0774 Uccelli a Associates, Inc. 650.952.8688 172 EXHIBIT C Ara Jabagchourian From: Ara Jabagchourian Sent: Thursday, November 4, 2021 8:55 PM To: L.M.Parmenter Subject: Re: error Msalam v. Sarbeland l Deponent Andrew Msalam While he was no longer available for deposition at 3:45 when he went to work for his 4 pm shift. How was going to I take a 2 hour deposition when he had left for work 15 minutes after his deposition was to start? When is heavailable for deposition? Sent from my iPhone On Nov 4, 2021, at 8:50 PM, L.M.Parmenter &Imparmenter@lawpar.corn& wrote: That is completely false. Julnar Msalam, Khalil Msalam and Andrew Msalam were all produced today, November 4, 2021, as per the notices of deposition of your clients. My clients and Iwent through great lengths to find one (1) deposition date as per your specific demand for all of three (3) depositions to take place on one (1) date. Iasked you several times to take the deposition on separate dates, but you angrily refused. Minor child Andrew Msalam normally works on this date and time and scheduled time to be available as per your notice and demand that his deposition be taken last at 3:30 p.m. You noticed Andrew Msalam's deposition for 3:30 p.m. and you continued to take the deposition of Khalil Msalam until the time frame of 5 p.m. ~TT~ Ligia M. Parmenter, Esq. 501 '8'treet, Ste. 200 Parmenter Law Offices San Rafae I, CA 94901 Tel/Fax: (415) 738-7901 Attorneys at 1.aw You should not file this email with publicly accessible records. CONFIDENTIALITY NOTICE: This electronic message is intended to be viewed only by the individual or entity to whom it is addressed. It may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this communication is strictly prohibited without our prior permission. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, or if you have received this communication in error, please notify us immediately by reply to this e-mail and delete the original message and any copies of itfrom your computer system. EMAIL WARNING/DISCLAIMER OF WARRANTEE/WAIVER OF RIGHTS: Although the Parmenter Law Offices has taken reasonable precautions to limit the presence of viruses in all email transmissions, this office does not warrant any transmission received as being virus free, and disclaims any liability for losses or damages arising from the use of this email or its attachments. Recipients of email "assume the risk" of possible computer virus exposure by opening or utilizing the email and its attachments, and waives any right or recourse against the Parmenter Law Offices by doing so. TRANSLATION DISCLAIMER: The Parmenter Law Offices uses Google Translation to convert from English to another language. Google Translation provides an automated translation. Since the translations are generated by machines, not all translation will be perfect. As a result, sometimes the translation may lose some of its intended meaning. Therefore, the Parmenter Law Offices cannot guarantee the accuracy of the converted text. Where there is any question, the English version is always the authoritative version. Some items may not be translated, such as images containing text, documents, maps, and other elements. In addition, some features may not work in the translated versions. If you have any questions about information that appears on our site, please contact the Parmenter Law Offices. On Thursday, November 4, 2021, 08:24:29 PM PDT, Ara Jabagchourian &ara@arajlaw.corn& wrote: No. He was not produced. In fact,he was noticed for a 3:30 deposition and he had leff for his job shift at Roundtable at 4 pm, Quit making facts up. Because you write it does not make it true. Sent from my iPhone On Nov 4, 2021, at 8:08 PM, L.M.Parmenter &ImparmenterOlawpar.corn& wrote: My apologies, I neglected to write the word "lvir."prior to your last name. --- Forwarded Message--- From: L.M.Parmenter &Imparmenter@lawpar.corn& To: Ara Jabagchourian &araOarajlaw.corn& Cc: Manny Juarez &baylawt@yahoo.corn&; Cynthia Anaya &cynthiaoaerlegal.corn&; Anthony E. Rodriguez &anthony@aerlegal.corn& Sent: Thursday, November 4, 2021, 08:05:54 PM PDT Subject: Msalam v. Sarbeland l Deponent Andrew Msalam Dear Jabagchorian: This shall confirm that pursuant to the deposition notice of your clients', minor child Andrew Msalam, was produced for his deposition which was noticed for November 4, 2021 at 3:30 p.m. That deposition did not take place due to your need to continue to take the deposition of Mr. Khalil Msalam unit 5 p.m. Very truly yours, Ligia M. Parmenter Ligia M. Parrnentar, Esq.