Motion,Ex Parte: GABRIEL FLORES VS MEDICALI HOLDINGS, INC.

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 08/31/2020 11:47 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk


               1 Justin Toobi, Esq. (SBN: 296174)
                 724 S. Spring St., Suite 201
               2 Los  Angeles, CA 90014
                 Telephone: (310) 435-9407
               3 Attorney for Plaintiff,
               4 GABRIEL FLORES
               5                                                      SUPERIOR COURT OF CALIFORNIA
               6                                         COUNTY OF LOS ANGELES - CENTRAL DISTRICT
               7
                      GABRIEL FLORES, an individual                                                  Case No. 19STCV31058
               8 Plaintiff,
                                                                                                     Assigned to Dept. 52, Hon., Susan Bryant-Deason,
               9        vs.                                                                          Judge Presiding
             10 MEDICALI HOLDINGS INC., a California
                                                                                                     NOTICE OF MOTION AND MOTION TO
             11 corporation, CHARLES WEINBERGER, an
                individual, MEDICALI HOLDINGS INC., a                                                STRIKE AND/OR TAX POST-JUDGMENT
                                                                                                     COSTS
             12 Nevada corporation, and DOES 2-10, inclusive,
             13 Defendants.
                                                                                                          Hearing:
             14                                                                                           Date:                        October 13, 2020
                                                                                                          Time:                        9:30 AM
             15                                                                                           Reservation ID:              119766335192
             16
                                TO THE HONORABLE COURT, DEFENDANTS, AND THEIR COUNSEL OF RECORD:
             17
                                PLEASE TAKE NOTICE that on October 13, 2020 at 9:30 A.M., before the Honorable Susan
             18
                    Bryant-Deason in Department 52 of the Superior Court of California, County of Los Angeles, Stanley
             19
                    Mosk Courthouse located at 111 N. Hill St., Los Angeles, CA 90012, Plaintiff GABRIEL FLORES will
             20
             21 move and hereby does move the court for an order to strike and/or tax the costs claimed by Defendant
             22 MEDICALI HOLDINGS INC., a California corporation in its memorandum of costs after judgment.
             23                 This Motion will be made pursuant to Code of Civil Procedure sections 685.040 and 685.070 on

             24 the grounds that a) Defendant’s memorandum was untimely, b) Defendant is not entitled to attorney fees in
             25 enforcing a sanctions order, and c) Defendant’s costs are not reasonable and should be taxed. This motion
             26 is based upon this Notice of Motion and Motion, the Memorandum of Points and Authorities, and
             27 Declaration of Justin Toobi, Esq. attached hereto along supporting exhibits, the complete records and files
             28 of this action, and any such other and further oral or documentary evidence that may be presented at the


                                                                                                      1

                                              PLAINTIFF’S MOTION TO STRIKE AND/OR TAX POST-JUDGMENT COSTS