Preview
1 Stephen B. Heath - 237622
sheath@heathandyuen.com Electronically Filed
2 Steven W. Yuen - 230768 Superior Court of California
syuen@heathandyuen.com County of San Joaquin
3 Lucy K. Galek - 227237 2022-02-15 14:51:46
lgalek@heathandyuen.com Clerk: Irving Jimenez
4 HEATH & YUEN, APC
268 Bush Street, #3006
5 San Francisco, CA 94104
Tel: (415) 622-7004
6 Fax: (415) 373-3957
7 Attorneys for Defendants/Cross-Complainants
GREWAL CARGO INC, CHARANJEET SINGH,
8 AND TAJINDER SINGH NAMED AS DOE 3
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN JOAQUIN
11 JOE EDWIN TAYLOR III, AN INCOMPETENT Case No.: STK-CV-UAT-2021-0001576
ADULT, BY AND THROUGH HIS
12 GUARDIAN AD LITEM TELISHA L. MOORE, EXHIBIT INDEX AND EXHIBITS IN
SUPPORT OF GREWAL CARGO INC’S
13 Plaintiffs, OPPOSITION TO PLAINTIFF’S MOTION
TO COMPEL FURTHER RESPONSES TO
14 v. SPECIAL INTERROGATORIES, SET NO. 2
15 GREWAL CARGO INC.; CHARANJEET Date: March 1, 2022
SINGH; AND DOES 1 THROUGH 150, Time: 9:00 a.m.
16 INCLUSIVE, Dept. 11B
17 Defendants.
18
AND ALL OTHER ACTIONS.
19
20 Document Name Exhibit
21 Declaration of Lucy K. Galek ................................................................................................................ A
22 Plaintiff’s Case Management Statement ................................................................................................ B
23 Meet and Confer ............................................................................................................................ C
24 Meet and Confer ............................................................................................................................ D
25 Meet and Confer ............................................................................................................................ E
26 ///
27 ///
28 ///
-1-
EXHIBIT INDEX AND EXHIBITS IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S
MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET NO. 2
1 DATED: February 15, 2022
HEATH & YUEN, APC
2
3
By
4 Lucy K. Galek
Attorneys for Defendants/Cross Complainants
5 GREWAL CARGO INC, CHARANJEET SINGH,
AND TAJINDER SINGH NAMED AS DOE 3
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-2-
EXHIBIT INDEX AND EXHIBITS IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S
MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET NO. 2
1 Stephen B. Heath - 237622
sheath@heathandyuen.com
2 Steven W. Yuen - 230768
syuen@heathandyuen.com
3 Lucy K. Galek - 227237
lgalek@heathandyuen.com
4 HEATH & YUEN, APC
268 Bush Street, #3006
5 San Francisco, CA 94104
Tel: (415) 622-7004
6 Fax: (415) 373-3957
7 Attorneys for Defendants/Cross-Complainants
GREWAL CARGO INC, CHARANJEET SINGH,
8 AND TAJINDER SINGH NAMED AS DOE 3
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN JOAQUIN
11 JOE EDWIN TAYLOR III, AN INCOMPETENT Case No.: STK-CV-UAT-2021-0001576
ADULT, BY AND THROUGH HIS
12 GUARDIAN AD LITEM TELISHA L. MOORE, DECLARATION OF LUCY K. GALEK IN
SUPPORT OF GREWAL CARGO INC’S
13 Plaintiffs, OPPOSITION TO PLAINTIFF’S MOTION
TO COMPEL FURTHER RESPONSES TO
14 v. SPECIAL INTERROGATORIES
15 GREWAL CARGO INC.; CHARANJEET Date: March 1, 2022
SINGH; AND DOES 1 THROUGH 150, Time: 9:00 a.m.
16 INCLUSIVE, Dept. 11B
17 Defendants.
18
AND ALL OTHER ACTIONS.
19
20 I, Lucy K. Galek, declare:
21 1. I am an attorney duly licensed to practice in all courts of the State of California, and am
22 a junior party in the law firm of Heath & Yuen, APC, attorneys of record for defendant/cross-
23 complainant Grewal Cargo Inc. (“Grewal”.) I have personal knowledge of the information set forth
24 herein, all of which is true and correct of my own personal knowledge, and if called upon to testify, I
25 could and would competently testify thereto.
26 2. I am the handling attorney on this case and have been personally involved in the
27 discovery meet and confer efforts.
28 3. Based on my telephone and email meet and confers with plaintiff’s counsel Ron Torem,
-1- Exhibit A
DECLARATION OF LUCY K. GALEK IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S
MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES
1 we resolved the discovery dispute concerning my client’s Grewal’s Response to Plaintiff’s Special
2 Interrogatories, Set One, and narrowed the scope of the discovery dispute on Grewal’s Response to
3 Plaintiff’s Demand For Production, Set Two, on October 13, 2021, which refer to Demands 85 and 86,
4 to:
5 “…responses to RFP attesting to the authenticity of the bills of lading indicating FAGE
Inc as the shipper and Silchuk Logisics as the broker. The copies of the bills of lading
6 must include copies of the back side. We will also need the shipper broker/carrier
agreement between FAGE and Silchuk for these bills of lading as well as the Broker
7 motor carrier agreement between Shilchuk and Grewal for these bills of lading and any
other contract whether shipper broker or shipper carrier “in effect” between FAGE,
8 Silchuck and Grewal, directly or indirectly, at the time these loads where consigned.”
9 4. Attached to the Exhibit Index as Exhibit B is plaintiff’s case management statement
10 admitting to the settlement.
11 5. Attached to the Exhibit Index as Exhibit C is a true and correct copy of my September
12 30, 2021 meet and confer correspondence memorializing the limitation of the discovery dispute to only
13 written discovery concerning the existence of a broker and a cop of the contract.
14 6. Attached to the Exhibit Index as Exhibit D is a true and correct copy of a meet and
15 confer correspondence chain in which I was a party to each item. It extends the deadline for the motion
16 to compel further response to the document demand, but not the special interrogatories, as that item
17 was resolved.
18 7. Attached to the Exhibit Index as Exhibit E is a true and correct copy of a meet and
19 confer correspondence chain in which I was a party to each item. It extends the deadline for the motion
20 to compel further response to the document demand. The entire chain refers only to the demand for
21 production. No corresponding extension were provided for the making of plaintiff’s motion to compel
22 further responses to his special interrogatories, set two.
23 I declare under penalty of perjury under the laws of the State of California the foregoing is true
24 and correct, and this declaration was executed on February 15, 2022.
25
26
______________________________________
27 Lucy K. Galek
28
-2-
DECLARATION OF LUCY K. GALEK IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S
MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES
Exhibit B
2/15/22, 3:23 AM Mail - Lucy Galek - Outlook
Taylor: meet and confer outcome
Lucy Galek
Thu 9/30/2021 2:33 PM
To: ront@torem.com
Cc: Wendy Yang ; DTorem@Torem.com
Bcc: _S00712: Taylor v. Grewal Cargo (a1a48a8c7+matter1376533141@maildrop.clio.com)
Ron,
Thank you for speaking with me today. This confirms our call. If any of this does not comport with your recollection, please advise.
Discovery dispute
We agreed that my client may provide the broker information and bills of lading informally. We further agreed that we will seek and provide
information on whether a contract with the broker exists, and a copy of the contract. We also agreed that my clients have two additional weeks
to provide their written responses, which makes the further responses due on and including October 15, 2021, and plaintiff shall have a
corresponding two-week extension on his motion to compel.
Interpleader
You said you will look at this and get back to us on the stipulation.
POA/Custodianship
I have withdrawn my request on these items as the court has accepted Ms. Moore as plaintiff's guardian.
Thanks, and I look forward to hearing from you regarding the stipulation.
Lucy
Lucy K. Galek | Jr. Partner
lgalek@heathandyuen.com t: (415) 429-4158
Bakersfield
He San Francisco Los Angeles San Diego Office Arizona Office
4900 California Ave.
ath & 268 Bush St., #3006 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
Tower B, 2nd Floor
Yuen San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
Bakersfield, CA 93309
T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact
us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
Exhibit C
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAFkAWkoNRaZNmXl5NR4Ofug%3D 1/1
2/15/22, 3:25 AM Mail - Lucy Galek - Outlook
RE: Taylor: meet and confer and further information for settlement approval
ront@torem.com
Wed 10/13/2021 9:51 AM
To: Lucy Galek
Cc: Wendy Yang ; DTorem@Torem.com ; ytorem@aol.com ; l2@torem.com
Agreed your further responses to RFP set 2 are now due on or before October 29, 2021 and our motion deadline is now November 15, 2021. Thank you
Please consider this as our office’s notice of acceptance of electronic service. Although you should reply to sender, in order for matters to be
calandared, any and all correspondence, pleadings, and discovery, MUST ALSO BE SENT TO:
toremlit@torem.com
Ron Torem
Torem & Associates
1607 Pontius Avenue
Los Angeles, California 90025
310-276-7878
ront@torem.com
"Since you can not do good to all, you are to pay special attention to those
who, by accident of time, or place, or circumstances, are brought into closer
connection with you."
St. Augustine of Hippo, ca. 4th Century CE
CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be
sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than
the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of
sending or receiving this message outside of a written agreement.
From: Lucy Galek
Sent: Wednesday, October 13, 2021 9:12 AM
To: ront@torem.com
Cc: Wendy Yang ; DTorem@Torem.com; ytorem@aol.com
Subject: Re: Taylor: meet and confer and further information for settlement approval
Hi Ron,
I can get can you the first two items quickly, but the last category will take more time. Please give us until October 29, 2021, which is two
additional weeks. We, of course, extend your motion to compel deadline by an additional and corresponding two weeks.
Please confirm your agreement.
Thanks,
Lucy
He Lucy K. Galek | Jr. Partner
ath & lgalek@heathandyuen.com t: (415) 429-4158
Yuen
San Francisco Bakersfield Los Angeles
Exhibit
San Diego Office
D
Arizona Office
268 Bush St., #3006 4900 California Ave. 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAIfSNzcaPE%2FHgQg2rO%2F3rek%3D 1/3
2/15/22, 3:25 AM Mail - Lucy Galek - Outlook
San Francisco, CA 94104 Tower B, 2nd Floor Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
T: (415) 622-7004 Bakersfield, CA 93309 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact
us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
From: ront@torem.com
Sent: Wednesday, October 13, 2021 9:06 AM
To: Lucy Galek
Cc: Wendy Yang ; DTorem@Torem.com ; ytorem@aol.com
Subject: RE: Taylor: meet and confer and further information for settlement approval
Lucy,
Thank you for getting me the bills of lading. We will need to get verified responses to RFP attesting to the authenticity of the bills of lading indicating
FAGE Inc as the shipper and Silchuk Logistics as the broker. The copies of the bills of lading must include copies of the back side. We will also need the
shipper broker/carrier agreement between FAGE and Silchuk for these bills of lading as well as the Broker motor carrier agreement between Shilchuk
and Grewal for these bills of lading and any other contract whether shipper broker or shipper carrier “in effect” between FAGE, Silchuck and Grewal,
directly or indirectly, at the time these loads where consigned. Per our meet and confer agreement your further responses are due on October 15, 2021
and our motion deadline is October 29, 2021.
Should you need additional time to get us the verified responses please let me know.
Please consider this as our office’s notice of acceptance of electronic service. Although you should reply to sender, in order for matters to be
calandared, any and all correspondence, pleadings, and discovery, MUST ALSO BE SENT TO:
toremlit@torem.com
Ron Torem
Torem & Associates
1607 Pontius Avenue
Los Angeles, California 90025
310-276-7878
ront@torem.com
"Since you can not do good to all, you are to pay special attention to those
who, by accident of time, or place, or circumstances, are brought into closer
connection with you."
St. Augustine of Hippo, ca. 4th Century CE
CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be
sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than
the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of
sending or receiving this message outside of a written agreement.
From: Lucy Galek
Sent: Tuesday, October 12, 2021 9:40 AM
To: ront@torem.com
Cc: Wendy Yang
Subject: Taylor: further information for settlement approval
Thanks for your patience, Ron. I did not have secure internet while I was away.
As we discussed, these items are being provided for the court's settlement approval purposes.
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAIfSNzcaPE%2FHgQg2rO%2F3rek%3D 2/3
2/15/22, 3:25 AM Mail - Lucy Galek - Outlook
The broker was Silchuk Logistics. The bills of lading for items being transported at the time of the subject collision are attached.
Lucy K. Galek | Jr. Partner
lgalek@heathandyuen.com t: (415) 429-4158
Bakersfield
He San Francisco Los Angeles San Diego Office Arizona Office
ath & 4900 California Ave.
268 Bush St., #3006 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
Yuen
Tower B, 2nd Floor
San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
Bakersfield, CA 93309
T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact
us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAIfSNzcaPE%2FHgQg2rO%2F3rek%3D 3/3
2/15/22, 3:22 AM Mail - Lucy Galek - Outlook
Re: Taylor v. Grewal Cargo
Lucy Galek
Wed 12/1/2021 2:40 PM
To: ront@torem.com ; DTorem@Torem.com ; l2@torem.com
Cc: Wendy Yang ; ytorem@aol.com
Bcc: _S00712: Inc.
Confirmed.
Lucy K. Galek | Jr. Partner
lgalek@heathandyuen.comt: (415) 429-4158
Bakersfield
He San Francisco Los Angeles San Diego Office Arizona Office
4900 California Ave.
ath & 268 Bush St., #3006 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
Tower B, 2nd Floor
Yuen San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
Bakersfield, CA 93309
T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact
us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
From: ront@torem.com
Sent: Wednesday, December 1, 2021 2:08 PM
To: Lucy Galek ; DTorem@Torem.com ; l2@torem.com
Cc: Wendy Yang ; ytorem@aol.com
Subject: RE: Taylor v. Grewal Cargo
With the holidays coming on I don’t want to have to do a motion on Christmas Eve. So we agree to a further extension subject to your agreeing that
Plaintiffs motion cut off date will be January 15, 2022. Please confirm by reply email. Thank you
Ron Torem
Torem & Associates
1607 Pontius Avenue
Los Angeles, California 90025
310-276-7878
ront@torem.com
"Since you can not do good to all, you are to pay special attention to those
who, by accident of time, or place, or circumstances, are brought into closer
connection with you."
St. Augustine of Hippo, ca. 4th Century CE
CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be
sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the
intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of
sending or receiving this message outside of a written agreement.
From: Lucy Galek
Sent: Wednesday, December 1, 2021 1:02 PM
To: ront@torem.com; DTorem@Torem.com; l2@torem.com
Cc: Wendy Yang ; ytorem@aol.com
Subject: Re: Taylor v. Grewal Cargo
Exhibit E
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 1/4
2/15/22, 3:22 AM Mail - Lucy Galek - Outlook
My client is not responding. I propose two more weeks to 12/15/21 for my client to provide responses, and to December 31 for your client to
bring a motion to compel. I am attempting and hopeful that we may reestablish contact.
Thanks,
Lucy
Lucy K. Galek | Jr. Partner
lgalek@heathandyuen.comt: (415) 429-4158
Bakersfield
He San Francisco Los Angeles San Diego Office Arizona Office
4900 California Ave.
ath & 268 Bush St., #3006 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
Yuen Tower B, 2nd Floor
San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
Bakersfield, CA 93309
T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact
us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
From: ront@torem.com
Sent: Monday, November 29, 2021 10:13 AM
To: Lucy Galek ; DTorem@Torem.com ; l2@torem.com
Cc: Wendy Yang ; ytorem@aol.com
Subject: RE: Taylor v. Grewal Cargo
Lucy please advise if you will be providing further responses to Request for Production of Documents Set 2 today as agreed in our prior meet and confers
below. Thank you.
Please consider this as our office’s notice of acceptance of electronic service. Although you should reply to sender, in order for matters to be
calandared, any and all correspondence, pleadings, and discovery, MUST ALSO BE SENT TO:
toremlit@torem.com
Ron Torem
Torem & Associates
1607 Pontius Avenue
Los Angeles, California 90025
310-276-7878
ront@torem.com
"Since you can not do good to all, you are to pay special attention to those
who, by accident of time, or place, or circumstances, are brought into closer
connection with you."
St. Augustine of Hippo, ca. 4th Century CE
CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be
sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the
intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of
sending or receiving this message outside of a written agreement.
From: Lucy Galek
Sent: Monday, November 8, 2021 10:07 AM
To: ront@torem.com; DTorem@Torem.com; l2@torem.com
Cc: Wendy Yang ; ytorem@aol.com
Subject: Re: Taylor v. Grewal Cargo
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 2/4
2/15/22, 3:22 AM Mail - Lucy Galek - Outlook
Confirmed. Thank you, Ron.
Lucy K. Galek | Jr. Partner
lgalek@heathandyuen.comt: (415) 429-4158
He Bakersfield
ath & San Francisco Los Angeles San Diego Office Arizona Office
4900 California Ave.
Yuen 268 Bush St., #3006 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
Tower B, 2nd Floor
San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
Bakersfield, CA 93309
T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact
us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
From: ront@torem.com
Sent: Monday, November 8, 2021 10:00 AM
To: Lucy Galek ; DTorem@Torem.com ; l2@torem.com
Cc: Wendy Yang ; ytorem@aol.com
Subject: RE: Taylor v. Grewal Cargo
Sorry to hear about your clients loss. That’s fine on the extension though we would like to have an additional 3 weeks as well for filing the motion in the
event the discovery dispute is not resolved. Your responses are now due November 29, 2021 and our last day to file a motion to compel is December 20,
2021. Please confirm your agreement by reply email. Thank you
Ron Torem
Torem & Associates
1607 Pontius Avenue
Los Angeles, California 90025
310-276-7878
ront@torem.com
"Since you can not do good to all, you are to pay special attention to those
who, by accident of time, or place, or circumstances, are brought into closer
connection with you."
St. Augustine of Hippo, ca. 4th Century CE
CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be
sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the
intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of
sending or receiving this message outside of a written agreement.
From: Lucy Galek
Sent: Monday, November 8, 2021 9:03 AM
To: ront@torem.com; DTorem@Torem.com; l2@torem.com
Cc: Wendy Yang
Subject: Re: Taylor v. Grewal Cargo
Ron,
I have found out that my client contact has been out for the country for his father and brother's funeral, and is now caring for his mother. We
request another extension on the discovery responses as we would otherwise have to provide a response that our client has no access to contract
documents. We of course will offer a corresponding extension for the motion to compel.
I suggest that under these circumstances, with my client out of the country, that a three-week extension be provided so that Grewal's responses
are due on and including November 29, 2021, and plaintiff having until December 13, 2021 to compel further response.
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 3/4
2/15/22, 3:22 AM Mail - Lucy Galek - Outlook
Thank you for your patience.
Lucy
Lucy K. Galek | Jr. Partner
lgalek@heathandyuen.comt: (415) 429-4158
Bakersfield
He San Francisco Los Angeles San Diego Office Arizona Office
ath & 4900 California Ave.
268 Bush St., #3006 501 W. Broadway, Suite 800
633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203
Yuen San Francisco, CA 94104
Tower B, 2nd Floor
Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716
Bakersfield, CA 93309
T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004
T: (661) 622-9111
F: (415) 373-3957 www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us
by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
From: Wendy Yang
Sent: Friday, November 5, 2021 11:42 AM
To: ront@torem.com ; DTorem@Torem.com ; l2@torem.com
Cc: Lucy Galek
Subject: Taylor v. Grewal Cargo
Dear Counsel,
My client Grewal's further responses to plaintiff’s demand for production are due today, but our client is still conducting search for the
documents. We would like to obtain another two week extension, or until November 19, 2021 to provide the responses.
Please advise if the extension is okay.
Thank you,
Wendy H. Yang | Paralegal
wyang@heathandyuen.com t: (415) 622-7086
San Francisco Bakersfield Los Angeles San Diego Office Arizona Office
268 Bush St., #30064900 California Ave. 501 W. Broadway, Suite
633 W. Fifth St., Suite 6363 N. Swan STE 200
Heath & Yuen
San Francisco, CA 94104
Tower B, 2nd Floor 2600 800 Tucson, AZ 85718
San Diego, CA 92101
T: (415) 622-7004 Bakersfield, CA 93309
Los Angeles, CA 90071 T: (415) 622.7004
T: (619) 677-1488
T: (661) 622-9111 T: (310) 622-9809
F: (415) 373-3957 [www.heathandyuen.com]www.heathandyuen.com
Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this
communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments.
https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 4/4
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1 Stephen B. Heath - 237622 sheath@heathandyuen.com Electronically Filed 2 Steven W. Yuen - 230768 Superior Court of California syuen@heathandyuen.com County of San Joaquin 3 Lucy K. Galek - 227237 2022-02-15 14:51:46 lgalek@heathandyuen.com Clerk: Irving Jimenez 4 HEATH & YUEN, APC 268 Bush Street, #3006 5 San Francisco, CA 94104 Tel: (415) 622-7004 6 Fax: (415) 373-3957 7 Attorneys for Defendants/Cross-Complainants GREWAL CARGO INC, CHARANJEET SINGH, 8 AND TAJINDER SINGH NAMED AS DOE 3 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN JOAQUIN 11 JOE EDWIN TAYLOR III, AN INCOMPETENT Case No.: STK-CV-UAT-2021-0001576 ADULT, BY AND THROUGH HIS 12 GUARDIAN AD LITEM TELISHA L. MOORE, EXHIBIT INDEX AND EXHIBITS IN SUPPORT OF GREWAL CARGO INC’S 13 Plaintiffs, OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO 14 v. SPECIAL INTERROGATORIES, SET NO. 2 15 GREWAL CARGO INC.; CHARANJEET Date: March 1, 2022 SINGH; AND DOES 1 THROUGH 150, Time: 9:00 a.m. 16 INCLUSIVE, Dept. 11B 17 Defendants. 18 AND ALL OTHER ACTIONS. 19 20 Document Name Exhibit 21 Declaration of Lucy K. Galek ................................................................................................................ A 22 Plaintiff’s Case Management Statement ................................................................................................ B 23 Meet and Confer ............................................................................................................................ C 24 Meet and Confer ............................................................................................................................ D 25 Meet and Confer ............................................................................................................................ E 26 /// 27 /// 28 /// -1- EXHIBIT INDEX AND EXHIBITS IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET NO. 2 1 DATED: February 15, 2022 HEATH & YUEN, APC 2 3 By 4 Lucy K. Galek Attorneys for Defendants/Cross Complainants 5 GREWAL CARGO INC, CHARANJEET SINGH, AND TAJINDER SINGH NAMED AS DOE 3 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- EXHIBIT INDEX AND EXHIBITS IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET NO. 2 1 Stephen B. Heath - 237622 sheath@heathandyuen.com 2 Steven W. Yuen - 230768 syuen@heathandyuen.com 3 Lucy K. Galek - 227237 lgalek@heathandyuen.com 4 HEATH & YUEN, APC 268 Bush Street, #3006 5 San Francisco, CA 94104 Tel: (415) 622-7004 6 Fax: (415) 373-3957 7 Attorneys for Defendants/Cross-Complainants GREWAL CARGO INC, CHARANJEET SINGH, 8 AND TAJINDER SINGH NAMED AS DOE 3 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN JOAQUIN 11 JOE EDWIN TAYLOR III, AN INCOMPETENT Case No.: STK-CV-UAT-2021-0001576 ADULT, BY AND THROUGH HIS 12 GUARDIAN AD LITEM TELISHA L. MOORE, DECLARATION OF LUCY K. GALEK IN SUPPORT OF GREWAL CARGO INC’S 13 Plaintiffs, OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO 14 v. SPECIAL INTERROGATORIES 15 GREWAL CARGO INC.; CHARANJEET Date: March 1, 2022 SINGH; AND DOES 1 THROUGH 150, Time: 9:00 a.m. 16 INCLUSIVE, Dept. 11B 17 Defendants. 18 AND ALL OTHER ACTIONS. 19 20 I, Lucy K. Galek, declare: 21 1. I am an attorney duly licensed to practice in all courts of the State of California, and am 22 a junior party in the law firm of Heath & Yuen, APC, attorneys of record for defendant/cross- 23 complainant Grewal Cargo Inc. (“Grewal”.) I have personal knowledge of the information set forth 24 herein, all of which is true and correct of my own personal knowledge, and if called upon to testify, I 25 could and would competently testify thereto. 26 2. I am the handling attorney on this case and have been personally involved in the 27 discovery meet and confer efforts. 28 3. Based on my telephone and email meet and confers with plaintiff’s counsel Ron Torem, -1- Exhibit A DECLARATION OF LUCY K. GALEK IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES 1 we resolved the discovery dispute concerning my client’s Grewal’s Response to Plaintiff’s Special 2 Interrogatories, Set One, and narrowed the scope of the discovery dispute on Grewal’s Response to 3 Plaintiff’s Demand For Production, Set Two, on October 13, 2021, which refer to Demands 85 and 86, 4 to: 5 “…responses to RFP attesting to the authenticity of the bills of lading indicating FAGE Inc as the shipper and Silchuk Logisics as the broker. The copies of the bills of lading 6 must include copies of the back side. We will also need the shipper broker/carrier agreement between FAGE and Silchuk for these bills of lading as well as the Broker 7 motor carrier agreement between Shilchuk and Grewal for these bills of lading and any other contract whether shipper broker or shipper carrier “in effect” between FAGE, 8 Silchuck and Grewal, directly or indirectly, at the time these loads where consigned.” 9 4. Attached to the Exhibit Index as Exhibit B is plaintiff’s case management statement 10 admitting to the settlement. 11 5. Attached to the Exhibit Index as Exhibit C is a true and correct copy of my September 12 30, 2021 meet and confer correspondence memorializing the limitation of the discovery dispute to only 13 written discovery concerning the existence of a broker and a cop of the contract. 14 6. Attached to the Exhibit Index as Exhibit D is a true and correct copy of a meet and 15 confer correspondence chain in which I was a party to each item. It extends the deadline for the motion 16 to compel further response to the document demand, but not the special interrogatories, as that item 17 was resolved. 18 7. Attached to the Exhibit Index as Exhibit E is a true and correct copy of a meet and 19 confer correspondence chain in which I was a party to each item. It extends the deadline for the motion 20 to compel further response to the document demand. The entire chain refers only to the demand for 21 production. No corresponding extension were provided for the making of plaintiff’s motion to compel 22 further responses to his special interrogatories, set two. 23 I declare under penalty of perjury under the laws of the State of California the foregoing is true 24 and correct, and this declaration was executed on February 15, 2022. 25 26 ______________________________________ 27 Lucy K. Galek 28 -2- DECLARATION OF LUCY K. GALEK IN SUPPORT OF GREWAL CARGO INC’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES Exhibit B 2/15/22, 3:23 AM Mail - Lucy Galek - Outlook Taylor: meet and confer outcome Lucy Galek Thu 9/30/2021 2:33 PM To: ront@torem.com Cc: Wendy Yang ; DTorem@Torem.com Bcc: _S00712: Taylor v. Grewal Cargo (a1a48a8c7+matter1376533141@maildrop.clio.com) Ron, Thank you for speaking with me today. This confirms our call. If any of this does not comport with your recollection, please advise. Discovery dispute We agreed that my client may provide the broker information and bills of lading informally. We further agreed that we will seek and provide information on whether a contract with the broker exists, and a copy of the contract. We also agreed that my clients have two additional weeks to provide their written responses, which makes the further responses due on and including October 15, 2021, and plaintiff shall have a corresponding two-week extension on his motion to compel. Interpleader You said you will look at this and get back to us on the stipulation. POA/Custodianship I have withdrawn my request on these items as the court has accepted Ms. Moore as plaintiff's guardian. Thanks, and I look forward to hearing from you regarding the stipulation. Lucy Lucy K. Galek | Jr. Partner lgalek@heathandyuen.com t: (415) 429-4158 Bakersfield He San Francisco Los Angeles San Diego Office Arizona Office 4900 California Ave. ath & 268 Bush St., #3006 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 Tower B, 2nd Floor Yuen San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 Bakersfield, CA 93309 T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. Exhibit C https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAFkAWkoNRaZNmXl5NR4Ofug%3D 1/1 2/15/22, 3:25 AM Mail - Lucy Galek - Outlook RE: Taylor: meet and confer and further information for settlement approval ront@torem.com Wed 10/13/2021 9:51 AM To: Lucy Galek Cc: Wendy Yang ; DTorem@Torem.com ; ytorem@aol.com ; l2@torem.com Agreed your further responses to RFP set 2 are now due on or before October 29, 2021 and our motion deadline is now November 15, 2021. Thank you Please consider this as our office’s notice of acceptance of electronic service. Although you should reply to sender, in order for matters to be calandared, any and all correspondence, pleadings, and discovery, MUST ALSO BE SENT TO: toremlit@torem.com Ron Torem Torem & Associates 1607 Pontius Avenue Los Angeles, California 90025 310-276-7878 ront@torem.com "Since you can not do good to all, you are to pay special attention to those who, by accident of time, or place, or circumstances, are brought into closer connection with you." St. Augustine of Hippo, ca. 4th Century CE CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of sending or receiving this message outside of a written agreement. From: Lucy Galek Sent: Wednesday, October 13, 2021 9:12 AM To: ront@torem.com Cc: Wendy Yang ; DTorem@Torem.com; ytorem@aol.com Subject: Re: Taylor: meet and confer and further information for settlement approval Hi Ron, I can get can you the first two items quickly, but the last category will take more time. Please give us until October 29, 2021, which is two additional weeks. We, of course, extend your motion to compel deadline by an additional and corresponding two weeks. Please confirm your agreement. Thanks, Lucy He Lucy K. Galek | Jr. Partner ath & lgalek@heathandyuen.com t: (415) 429-4158 Yuen San Francisco Bakersfield Los Angeles Exhibit San Diego Office D Arizona Office 268 Bush St., #3006 4900 California Ave. 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAIfSNzcaPE%2FHgQg2rO%2F3rek%3D 1/3 2/15/22, 3:25 AM Mail - Lucy Galek - Outlook San Francisco, CA 94104 Tower B, 2nd Floor Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 T: (415) 622-7004 Bakersfield, CA 93309 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. From: ront@torem.com Sent: Wednesday, October 13, 2021 9:06 AM To: Lucy Galek Cc: Wendy Yang ; DTorem@Torem.com ; ytorem@aol.com Subject: RE: Taylor: meet and confer and further information for settlement approval Lucy, Thank you for getting me the bills of lading. We will need to get verified responses to RFP attesting to the authenticity of the bills of lading indicating FAGE Inc as the shipper and Silchuk Logistics as the broker. The copies of the bills of lading must include copies of the back side. We will also need the shipper broker/carrier agreement between FAGE and Silchuk for these bills of lading as well as the Broker motor carrier agreement between Shilchuk and Grewal for these bills of lading and any other contract whether shipper broker or shipper carrier “in effect” between FAGE, Silchuck and Grewal, directly or indirectly, at the time these loads where consigned. Per our meet and confer agreement your further responses are due on October 15, 2021 and our motion deadline is October 29, 2021. Should you need additional time to get us the verified responses please let me know. Please consider this as our office’s notice of acceptance of electronic service. Although you should reply to sender, in order for matters to be calandared, any and all correspondence, pleadings, and discovery, MUST ALSO BE SENT TO: toremlit@torem.com Ron Torem Torem & Associates 1607 Pontius Avenue Los Angeles, California 90025 310-276-7878 ront@torem.com "Since you can not do good to all, you are to pay special attention to those who, by accident of time, or place, or circumstances, are brought into closer connection with you." St. Augustine of Hippo, ca. 4th Century CE CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of sending or receiving this message outside of a written agreement. From: Lucy Galek Sent: Tuesday, October 12, 2021 9:40 AM To: ront@torem.com Cc: Wendy Yang Subject: Taylor: further information for settlement approval Thanks for your patience, Ron. I did not have secure internet while I was away. As we discussed, these items are being provided for the court's settlement approval purposes. https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAIfSNzcaPE%2FHgQg2rO%2F3rek%3D 2/3 2/15/22, 3:25 AM Mail - Lucy Galek - Outlook The broker was Silchuk Logistics. The bills of lading for items being transported at the time of the subject collision are attached. Lucy K. Galek | Jr. Partner lgalek@heathandyuen.com t: (415) 429-4158 Bakersfield He San Francisco Los Angeles San Diego Office Arizona Office ath & 4900 California Ave. 268 Bush St., #3006 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 Yuen Tower B, 2nd Floor San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 Bakersfield, CA 93309 T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAIfSNzcaPE%2FHgQg2rO%2F3rek%3D 3/3 2/15/22, 3:22 AM Mail - Lucy Galek - Outlook Re: Taylor v. Grewal Cargo Lucy Galek Wed 12/1/2021 2:40 PM To: ront@torem.com ; DTorem@Torem.com ; l2@torem.com Cc: Wendy Yang ; ytorem@aol.com Bcc: _S00712: Inc. Confirmed. Lucy K. Galek | Jr. Partner lgalek@heathandyuen.comt: (415) 429-4158 Bakersfield He San Francisco Los Angeles San Diego Office Arizona Office 4900 California Ave. ath & 268 Bush St., #3006 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 Tower B, 2nd Floor Yuen San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 Bakersfield, CA 93309 T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. From: ront@torem.com Sent: Wednesday, December 1, 2021 2:08 PM To: Lucy Galek ; DTorem@Torem.com ; l2@torem.com Cc: Wendy Yang ; ytorem@aol.com Subject: RE: Taylor v. Grewal Cargo With the holidays coming on I don’t want to have to do a motion on Christmas Eve. So we agree to a further extension subject to your agreeing that Plaintiffs motion cut off date will be January 15, 2022. Please confirm by reply email. Thank you Ron Torem Torem & Associates 1607 Pontius Avenue Los Angeles, California 90025 310-276-7878 ront@torem.com "Since you can not do good to all, you are to pay special attention to those who, by accident of time, or place, or circumstances, are brought into closer connection with you." St. Augustine of Hippo, ca. 4th Century CE CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of sending or receiving this message outside of a written agreement. From: Lucy Galek Sent: Wednesday, December 1, 2021 1:02 PM To: ront@torem.com; DTorem@Torem.com; l2@torem.com Cc: Wendy Yang ; ytorem@aol.com Subject: Re: Taylor v. Grewal Cargo Exhibit E https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 1/4 2/15/22, 3:22 AM Mail - Lucy Galek - Outlook My client is not responding. I propose two more weeks to 12/15/21 for my client to provide responses, and to December 31 for your client to bring a motion to compel. I am attempting and hopeful that we may reestablish contact. Thanks, Lucy Lucy K. Galek | Jr. Partner lgalek@heathandyuen.comt: (415) 429-4158 Bakersfield He San Francisco Los Angeles San Diego Office Arizona Office 4900 California Ave. ath & 268 Bush St., #3006 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 Yuen Tower B, 2nd Floor San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 Bakersfield, CA 93309 T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. From: ront@torem.com Sent: Monday, November 29, 2021 10:13 AM To: Lucy Galek ; DTorem@Torem.com ; l2@torem.com Cc: Wendy Yang ; ytorem@aol.com Subject: RE: Taylor v. Grewal Cargo Lucy please advise if you will be providing further responses to Request for Production of Documents Set 2 today as agreed in our prior meet and confers below. Thank you. Please consider this as our office’s notice of acceptance of electronic service. Although you should reply to sender, in order for matters to be calandared, any and all correspondence, pleadings, and discovery, MUST ALSO BE SENT TO: toremlit@torem.com Ron Torem Torem & Associates 1607 Pontius Avenue Los Angeles, California 90025 310-276-7878 ront@torem.com "Since you can not do good to all, you are to pay special attention to those who, by accident of time, or place, or circumstances, are brought into closer connection with you." St. Augustine of Hippo, ca. 4th Century CE CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of sending or receiving this message outside of a written agreement. From: Lucy Galek Sent: Monday, November 8, 2021 10:07 AM To: ront@torem.com; DTorem@Torem.com; l2@torem.com Cc: Wendy Yang ; ytorem@aol.com Subject: Re: Taylor v. Grewal Cargo https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 2/4 2/15/22, 3:22 AM Mail - Lucy Galek - Outlook Confirmed. Thank you, Ron. Lucy K. Galek | Jr. Partner lgalek@heathandyuen.comt: (415) 429-4158 He Bakersfield ath & San Francisco Los Angeles San Diego Office Arizona Office 4900 California Ave. Yuen 268 Bush St., #3006 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 Tower B, 2nd Floor San Francisco, CA 94104 Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 Bakersfield, CA 93309 T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. From: ront@torem.com Sent: Monday, November 8, 2021 10:00 AM To: Lucy Galek ; DTorem@Torem.com ; l2@torem.com Cc: Wendy Yang ; ytorem@aol.com Subject: RE: Taylor v. Grewal Cargo Sorry to hear about your clients loss. That’s fine on the extension though we would like to have an additional 3 weeks as well for filing the motion in the event the discovery dispute is not resolved. Your responses are now due November 29, 2021 and our last day to file a motion to compel is December 20, 2021. Please confirm your agreement by reply email. Thank you Ron Torem Torem & Associates 1607 Pontius Avenue Los Angeles, California 90025 310-276-7878 ront@torem.com "Since you can not do good to all, you are to pay special attention to those who, by accident of time, or place, or circumstances, are brought into closer connection with you." St. Augustine of Hippo, ca. 4th Century CE CONFIDENTIALITY NOTICE: This e-mail is a confidential legally privileged communication and is intended to be sent only to the recipient stated therein. Any copying, disclosure, distribution, review or use of this e-mail by other than the intended recipient or that person's agent is strictly prohibited. No attorney-client relationship is created by the act of sending or receiving this message outside of a written agreement. From: Lucy Galek Sent: Monday, November 8, 2021 9:03 AM To: ront@torem.com; DTorem@Torem.com; l2@torem.com Cc: Wendy Yang Subject: Re: Taylor v. Grewal Cargo Ron, I have found out that my client contact has been out for the country for his father and brother's funeral, and is now caring for his mother. We request another extension on the discovery responses as we would otherwise have to provide a response that our client has no access to contract documents. We of course will offer a corresponding extension for the motion to compel. I suggest that under these circumstances, with my client out of the country, that a three-week extension be provided so that Grewal's responses are due on and including November 29, 2021, and plaintiff having until December 13, 2021 to compel further response. https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 3/4 2/15/22, 3:22 AM Mail - Lucy Galek - Outlook Thank you for your patience. Lucy Lucy K. Galek | Jr. Partner lgalek@heathandyuen.comt: (415) 429-4158 Bakersfield He San Francisco Los Angeles San Diego Office Arizona Office ath & 4900 California Ave. 268 Bush St., #3006 501 W. Broadway, Suite 800 633 W. Fifth St., Suite 2600 2701 East Speedway Blvd, Suite 203 Yuen San Francisco, CA 94104 Tower B, 2nd Floor Los Angeles, CA 90071 San Diego, CA 92101 Tucson, AZ 85716 Bakersfield, CA 93309 T: (415) 622-7004 T: (310) 622-9809 T: (619) 677-1488 T: (415) 622.7004 T: (661) 622-9111 F: (415) 373-3957 www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. From: Wendy Yang Sent: Friday, November 5, 2021 11:42 AM To: ront@torem.com ; DTorem@Torem.com ; l2@torem.com Cc: Lucy Galek Subject: Taylor v. Grewal Cargo Dear Counsel, My client Grewal's further responses to plaintiff’s demand for production are due today, but our client is still conducting search for the documents. We would like to obtain another two week extension, or until November 19, 2021 to provide the responses. Please advise if the extension is okay. Thank you, Wendy H. Yang | Paralegal wyang@heathandyuen.com t: (415) 622-7086 San Francisco Bakersfield Los Angeles San Diego Office Arizona Office 268 Bush St., #30064900 California Ave. 501 W. Broadway, Suite 633 W. Fifth St., Suite 6363 N. Swan STE 200 Heath & Yuen San Francisco, CA 94104 Tower B, 2nd Floor 2600 800 Tucson, AZ 85718 San Diego, CA 92101 T: (415) 622-7004 Bakersfield, CA 93309 Los Angeles, CA 90071 T: (415) 622.7004 T: (619) 677-1488 T: (661) 622-9111 T: (310) 622-9809 F: (415) 373-3957 [www.heathandyuen.com]www.heathandyuen.com Disclaimer: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. If you have received this e-mail in error, any disclosure, copying, distribution, or use of this communication is prohibited and we request that you contact us by reply email or call us at (415) 622-7004, and then destroy all copies of our original message and any attachments. https://outlook.office.com/mail/id/AAQkADk3OGYxMGI1LTBlZTQtNDg1ZS04ZGVjLWQ4MjZiZTI3NDRiMgAQAAb5ok3QUUJ4vsqAMBRsQ1A%3D 4/4