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Murray Tragish, Esq., CSB 480759
LAW OFFICES OF MURRAY TRAGISH
5330 Office Center Court, Suite 72
1405 Commercial Way, Suite 130
Bakersfield, California 93309
Tel: (661} 324-2648
E-Maik Mulray Murraytragish.corn
Ray T. Mullen, Esq., CSB 18111852
LAW OFFICE OF RAY T. MULLKN
California
5330 Office Center Court, Suite 32
Bakersfield, 93309
Tel: (661) 631-1531
E-Mail:Ray@Raymullen.corn
California
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Attorneys for Plaintif5'Cross-Defendant: Alder Mini Storage, L.P., a
Limited Partnership and
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Cross-Defendant: Derrel Ridenour
.12 SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF KERN, METROPOLITAN DISTRICT, CIVIL DIVISION
14
13
ALDAR MINI STORAGE, L,P., a California Case No. BCV-20-101265-BCB
limited partnership,
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NOTICE OF HEARING ON ALDAR MINI
STORAGE, L.P.'S AND DERREL
Plaintiff, RIDENOUR'8 MOTION FOR AN ORDER
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vs. STRIKING WORLD OF PENTECOST, INC.
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AKA WORLD OF PENTECOST-LIFE
THV ENTERPRISES, a California CHURCH'S ANSWER AND CROSS-
19 corporation; THV HAYKNARIK, LLC, a COMPLAINT, AND FOR ENTRY OF
California limited liability company; WORLD DEFAULT
20 OF PENTECOST, INC., a California non-
profit religious corporation, also known as Date of Hearing: March I, 2022
21 WORLD OF PENTECOST-LIFE CHURCH; Time of Hearing: 8:30 a.m.
Division: H
KHACHATUR GHASABYAN, an individual,
22 also known as CHRIS GHASABYAN;
TIGRAN ARUTYUNYAN, an individual; and
23 DOES 1through 500, inclusive,
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Defendants.
25
WORLD OF PENTECOST, INC., a Assigned to the Honorable Bernard C. Barmann
26 Action Filed: June 1, 2020
Cross-Complainant, Second Amended Complaint Filed: Dec. 21 2020
27 First Amended Cross-Complaint: May 24, 2021
Trial Date: May 23, 2022
28 vs.
NOTICE OF HEARING ON ALDAR MINI STORAGE, L.P.'S AND DERREL RIDENOUR'S MOTION FOR AN ORDER STRIKING
WORLD OF PENTECOST, INC. AKA WORLD OF PENTECOST LIFE CHURCH'S ANSWER AND CROSSCOMFLAINT
AND FOR
ENTRY OF DEFAULT
I
ALDAR MINI STORAGE, L.P., a
I
California limited partnership, DERRELL
2 RIDENOUR, an individual, HEIDI NELSON,
an individual, THV ENTERPRISES, a
3 California corporation; THV HAYKNARIK,
LLC, a California limited liability company;
4
ALDAR MINI STORAGE, L.P., a California
5 limited partnership, KHACHATUR
GHASABYAN, an individual, also known as
6 CHRIS GHASABYAN; TIGRAN
7
ARUTYUNYAN, All Person Unknown,
Claiming any Legal or Equitable Right, Title,
8 Estate, Lien, or Interest in the Property
Described in the Complaint or Cross-
9
Complaint Adverse to Cross-Complainant" s
IO
Title Thereto, and DOES I through 500,
inclusive,
ll
ICross)-Defendants.
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13 TO THE ABOVE-ENTITLED COURT, AND TO ALL PARTIES AND THEIR
14 ATTORNEYS OF RECORD:
15
NOTICE IS HEREBY GIVEN that on March I, 2022, at 8:30 a.m., or as soon thereafter as
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the matter may be heard, in Division H in the instant Court„ located at 1215 Truxtun Avenue,
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Bakersfield, California 93301, Plaintiff/Cross-Defendant: ALDAR MINI STORAGE, L.P., 8
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19 California limited partnership, and Cross-Defendant: Derrel Ridenour (hereinafter collectively
20 referred to as "Plaintiff/Cross-Defendants"), will and shall move for an Order Striking World of
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Pentecost, Inc. aka World of Pentecost-Life Church's (hereinafter collectively referred to a»
22
"WOP") Answer and First Amended Cross-Complaint, and For Entry of Default (hereinaftei
23
24
referred to as the "Motion" ).
25 This Motion is made on the gmunds that WOP, an alleged non-profit corporation, cannot
26
represent itself in these proceedings and that it is a suspended California corporation and does nol
27
have any right, power or privilege to prosecute or defend itself in these proceedings.
28
NOTICE OF HEARING ON ALDAR MINI STORAGE, LP.'S AND DERREL RI DENGUE'S MOTION FOR AN ORDER STRIKING
WORLD OF PENTECOST, INC. AKA WORLD OF PENTECOSTLIFE CHURCH'S ANSWER AND CROSS-COMPLAINT, AND FOR
ENTRY OF DEFAULT
2
This Motion is made and based upon this Motion and Notice of Hearing, the supporting
I
Declaration of Murray Tragish, and the Memorandum of Points and Authorities in support thereof,
and any and all oral and/or documentary evidence and argument as may be adduced at the time ot
4
the hearing of the Motion.
5
6
January,CC
Dated: 2022 ICES 0
8
FIC F
10
California
Murray Trat,
Cross-Defet
12 li
Defendant:
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27
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NOTICE OP 14EARING ON ALDAI& MINI STORAGE., LPUS AND DERREL RIDENOUR'S MOTION FOR AN ORDER STR! KING
WORLD OF PENTECOST, INC. AKA WOIU D OF I'ENTECOST LIFL'HURCII'S ANSWER AND CROSS COMPLAINT, AND FOR
ENTRY OF DEPAULT
3
PROOF OF SERVICE
Aldar Mini Storage, I. K vs. THV Enterprises, inc., et al.
Kern County Superior Court; Case No. BCV-20-10/265-SDS
STATE OF CALIFORNIA, COUNTY OF KERN
I am a citizen of the United States and employed in the County of Kem, State of California
and my business
address is 5330 Office Center Court, Suite 72, Bakersfield, California 93309; I am over the age of eighteen and not a
party to the within entitled action.
On January 25, 2022, I served the following document(s) described as: NOTICE OF HEARING ON ALDAR
MINI STORAGE. L.P.'S AND DKRREL RIDENOUR'S MOTION FOR AN ORDER STRIKING WORLD
OF PENTECOST. INC. AKA WORLD OF PENTECOST-LIFE CHURCH'S ANSWER AND CROSS-
COMPLAINT. AND FOR ENTRY OF DEFAULT, on the interested parties to said action or through their attorneys
of record, by placing a true copy thereof in a sealed envelope, addressed as shown below, by the following means:
(By Mail) By placing a true copy thereof, enclosed in a sealed envelope with postage thereon fully prepaid, for
collection and mailing on that date following ordinary business practices, in the llnited States Mail at the Law
Offices of Mun ay Tragish, Bakersfield, California, addressed as shown below. I am readily familiar with this
business's practicefor collectionand processing of correspondence for mailing with the U.S. Postal Service,
and inthe ordinary course of business correspondence would be deposited with the IJ.S.PostalService the
same day it was placed for collection and processing.
Attomev for Defendants/Cross-Defendants; "I'HV Enternrises. Incz TIIV klavknarik, ieLC
Khachaitur Ghasabyan„Tieran Arutvunvan
Ronald D. Dessy, Esq.
Dessy & Dessy APC
1301 "L" Street
Bakersfield, California 93301
Defendam: World Of Pentecost. Inc, aka World of Pentecost-Life Church
clo Kurt Johnson and I.inda Johnson
13061 Rosedale I-lighway
Bakersfield, California 93314
~Attom s for Cross-Comnlainant: World of Pentecost. Inc.
Thomas M. Alexander, Jr. Esq. Thomas M. Alexander, Jr. Fsq.
Alexander Law Offices Thomas Alexander Law Offices
468 N. Camden Drive, Suite 200 226 East Sixth Street
Beverly Hills, California90210 Beaumont, California 92223
XX (By Electronic Service) Complying with California Code of Civil Procedure tj 1010,6, caused each such
document(s) to be electronically served from amy@murtaytragish.corn to each addressee below. The file
transmission was reported as complete and a copy of the receipt will be maintained with the original
document(s) in our office.
Rond1952Qaaol.corn Ronald D. Dessy, Esq.
Kurtejohnson70@gmail.corn Kurt Johnson (World of Pentecost, Inc.)
aiexanderslaw@gmail.corn Thomas Alexanders, Jr., Esq.
correct, and that I am employed in the office of a memb
service was made. Executed on January 25, 2022, at B
fh f th'ion
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and
the
Preview
Murray Tragish, Esq., CSB 480759 LAW OFFICES OF MURRAY TRAGISH 5330 Office Center Court, Suite 72 1405 Commercial Way, Suite 130 Bakersfield, California 93309 Tel: (661} 324-2648 E-Maik Mulray Murraytragish.corn Ray T. Mullen, Esq., CSB 18111852 LAW OFFICE OF RAY T. MULLKN California 5330 Office Center Court, Suite 32 Bakersfield, 93309 Tel: (661) 631-1531 E-Mail:Ray@Raymullen.corn California 9 Attorneys for Plaintif5'Cross-Defendant: Alder Mini Storage, L.P., a Limited Partnership and 10 Cross-Defendant: Derrel Ridenour .12 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF KERN, METROPOLITAN DISTRICT, CIVIL DIVISION 14 13 ALDAR MINI STORAGE, L,P., a California Case No. BCV-20-101265-BCB limited partnership, 16 NOTICE OF HEARING ON ALDAR MINI STORAGE, L.P.'S AND DERREL Plaintiff, RIDENOUR'8 MOTION FOR AN ORDER 17 vs. STRIKING WORLD OF PENTECOST, INC. 18 AKA WORLD OF PENTECOST-LIFE THV ENTERPRISES, a California CHURCH'S ANSWER AND CROSS- 19 corporation; THV HAYKNARIK, LLC, a COMPLAINT, AND FOR ENTRY OF California limited liability company; WORLD DEFAULT 20 OF PENTECOST, INC., a California non- profit religious corporation, also known as Date of Hearing: March I, 2022 21 WORLD OF PENTECOST-LIFE CHURCH; Time of Hearing: 8:30 a.m. Division: H KHACHATUR GHASABYAN, an individual, 22 also known as CHRIS GHASABYAN; TIGRAN ARUTYUNYAN, an individual; and 23 DOES 1through 500, inclusive, 24 Defendants. 25 WORLD OF PENTECOST, INC., a Assigned to the Honorable Bernard C. Barmann 26 Action Filed: June 1, 2020 Cross-Complainant, Second Amended Complaint Filed: Dec. 21 2020 27 First Amended Cross-Complaint: May 24, 2021 Trial Date: May 23, 2022 28 vs. NOTICE OF HEARING ON ALDAR MINI STORAGE, L.P.'S AND DERREL RIDENOUR'S MOTION FOR AN ORDER STRIKING WORLD OF PENTECOST, INC. AKA WORLD OF PENTECOST LIFE CHURCH'S ANSWER AND CROSSCOMFLAINT AND FOR ENTRY OF DEFAULT I ALDAR MINI STORAGE, L.P., a I California limited partnership, DERRELL 2 RIDENOUR, an individual, HEIDI NELSON, an individual, THV ENTERPRISES, a 3 California corporation; THV HAYKNARIK, LLC, a California limited liability company; 4 ALDAR MINI STORAGE, L.P., a California 5 limited partnership, KHACHATUR GHASABYAN, an individual, also known as 6 CHRIS GHASABYAN; TIGRAN 7 ARUTYUNYAN, All Person Unknown, Claiming any Legal or Equitable Right, Title, 8 Estate, Lien, or Interest in the Property Described in the Complaint or Cross- 9 Complaint Adverse to Cross-Complainant" s IO Title Thereto, and DOES I through 500, inclusive, ll ICross)-Defendants. 12 13 TO THE ABOVE-ENTITLED COURT, AND TO ALL PARTIES AND THEIR 14 ATTORNEYS OF RECORD: 15 NOTICE IS HEREBY GIVEN that on March I, 2022, at 8:30 a.m., or as soon thereafter as 16 the matter may be heard, in Division H in the instant Court„ located at 1215 Truxtun Avenue, 17 Bakersfield, California 93301, Plaintiff/Cross-Defendant: ALDAR MINI STORAGE, L.P., 8 18 19 California limited partnership, and Cross-Defendant: Derrel Ridenour (hereinafter collectively 20 referred to as "Plaintiff/Cross-Defendants"), will and shall move for an Order Striking World of 21 Pentecost, Inc. aka World of Pentecost-Life Church's (hereinafter collectively referred to a» 22 "WOP") Answer and First Amended Cross-Complaint, and For Entry of Default (hereinaftei 23 24 referred to as the "Motion" ). 25 This Motion is made on the gmunds that WOP, an alleged non-profit corporation, cannot 26 represent itself in these proceedings and that it is a suspended California corporation and does nol 27 have any right, power or privilege to prosecute or defend itself in these proceedings. 28 NOTICE OF HEARING ON ALDAR MINI STORAGE, LP.'S AND DERREL RI DENGUE'S MOTION FOR AN ORDER STRIKING WORLD OF PENTECOST, INC. AKA WORLD OF PENTECOSTLIFE CHURCH'S ANSWER AND CROSS-COMPLAINT, AND FOR ENTRY OF DEFAULT 2 This Motion is made and based upon this Motion and Notice of Hearing, the supporting I Declaration of Murray Tragish, and the Memorandum of Points and Authorities in support thereof, and any and all oral and/or documentary evidence and argument as may be adduced at the time ot 4 the hearing of the Motion. 5 6 January,CC Dated: 2022 ICES 0 8 FIC F 10 California Murray Trat, Cross-Defet 12 li Defendant: 13 13 16 17 18 19 20 21 22 23 'I4 25 27 28 NOTICE OP 14EARING ON ALDAI& MINI STORAGE., LPUS AND DERREL RIDENOUR'S MOTION FOR AN ORDER STR! KING WORLD OF PENTECOST, INC. AKA WOIU D OF I'ENTECOST LIFL'HURCII'S ANSWER AND CROSS COMPLAINT, AND FOR ENTRY OF DEPAULT 3 PROOF OF SERVICE Aldar Mini Storage, I. K vs. THV Enterprises, inc., et al. Kern County Superior Court; Case No. BCV-20-10/265-SDS STATE OF CALIFORNIA, COUNTY OF KERN I am a citizen of the United States and employed in the County of Kem, State of California and my business address is 5330 Office Center Court, Suite 72, Bakersfield, California 93309; I am over the age of eighteen and not a party to the within entitled action. On January 25, 2022, I served the following document(s) described as: NOTICE OF HEARING ON ALDAR MINI STORAGE. L.P.'S AND DKRREL RIDENOUR'S MOTION FOR AN ORDER STRIKING WORLD OF PENTECOST. INC. AKA WORLD OF PENTECOST-LIFE CHURCH'S ANSWER AND CROSS- COMPLAINT. AND FOR ENTRY OF DEFAULT, on the interested parties to said action or through their attorneys of record, by placing a true copy thereof in a sealed envelope, addressed as shown below, by the following means: (By Mail) By placing a true copy thereof, enclosed in a sealed envelope with postage thereon fully prepaid, for collection and mailing on that date following ordinary business practices, in the llnited States Mail at the Law Offices of Mun ay Tragish, Bakersfield, California, addressed as shown below. I am readily familiar with this business's practicefor collectionand processing of correspondence for mailing with the U.S. Postal Service, and inthe ordinary course of business correspondence would be deposited with the IJ.S.PostalService the same day it was placed for collection and processing. Attomev for Defendants/Cross-Defendants; "I'HV Enternrises. Incz TIIV klavknarik, ieLC Khachaitur Ghasabyan„Tieran Arutvunvan Ronald D. Dessy, Esq. Dessy & Dessy APC 1301 "L" Street Bakersfield, California 93301 Defendam: World Of Pentecost. Inc, aka World of Pentecost-Life Church clo Kurt Johnson and I.inda Johnson 13061 Rosedale I-lighway Bakersfield, California 93314 ~Attom s for Cross-Comnlainant: World of Pentecost. Inc. Thomas M. Alexander, Jr. Esq. Thomas M. Alexander, Jr. Fsq. Alexander Law Offices Thomas Alexander Law Offices 468 N. Camden Drive, Suite 200 226 East Sixth Street Beverly Hills, California90210 Beaumont, California 92223 XX (By Electronic Service) Complying with California Code of Civil Procedure tj 1010,6, caused each such document(s) to be electronically served from amy@murtaytragish.corn to each addressee below. The file transmission was reported as complete and a copy of the receipt will be maintained with the original document(s) in our office. Rond1952Qaaol.corn Ronald D. Dessy, Esq. Kurtejohnson70@gmail.corn Kurt Johnson (World of Pentecost, Inc.) aiexanderslaw@gmail.corn Thomas Alexanders, Jr., Esq. correct, and that I am employed in the office of a memb service was made. Executed on January 25, 2022, at B fh f th'ion I declare under penalty of perjury under the laws of the State of California that the foregoing is true and the