Party Discovery: SHINA PARKER VS INNOVATIVE SPEECH THERAPY AND COMMUNICATION SERVICES, INC., A CALIFORNIA CORPORATION

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 05/09/2022 08:30 AM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariano,Deputy Clerk




                          Kaveh S. Elihu, Esq. (SBN 268249)
                    1
                          Rhett Francisco, Esq. (SBN232749)
                    2     Daniel Friedman, Esq. (SBN289670)
                          EMPLOYEE JUSTICE LEGAL GROUP, PC
                    3     1001 Wilshire Boulevard
                          Los Angeles, California 90017
                    4
                          Telephone: (213) 382-2222
                    5     Facsimile: (213) 382-2230

                    6     Attorneys for Plaintiff,
                          SHINA PARKER
                    7
                                                           SUPERIOR COURT OF THE STATE OF CALIFORNIA,
                    8
                                                    FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
                    9
                  10       SHINA PARKER, an individual,
                                                                                                        Case No.: 19STCV36310
                  11                                         Plaintiff,                                 [Assigned for all purposes to Hon. Lawrence P. Riff,
                                                                                                        Dept. 51]
                  12                             vs.
                           INNOVATIVE SPEECH THERAPY AND
                  13       COMMUNICATION SERVICES, INC., a                                              DECLARATION OF DANIEL J. FRIEDMAN
                           California corporation; and DOES 1 through                                   RE: INABILITY TO FILE JOINT TRIAL
                  14                                                                                    DOCUMENTS
                           20, inclusive,
                  15                                                                                    FSC:
                                                                                                        Date: May 12, 2022
                  16                             Defendants.                                            Time: 8:30 a.m.
                                                                                                        Dept: 51
                  17
                                                                                                        Action filed: Damages 10, 2019
                  18                                                                                    Trial date: May 24, 2022
                  19                  I, Daniel J. Friedman, declare as follows:
                  20                  1.         I am an attorney at law licensed to practice before all courts of the State of California,
                  21      and am associated with the Employee Justice Legal Group, PC, (“EJLG”) counsel for Plaintiff herein.
                  22      I have personal knowledge of the facts set forth herein, and if called upon as a witness I could and

                  23      would testify competently thereto. I file this declaration to explain Plaintiff’s inability to prepare joint

                  24      trial documents, and why Plaintiffs submitted trial documents on her own behalf, only.

                  25                  2.         On May 4, 2022, I emailed Mr. Schmidt to meet and confer regarding the joint trial

                  26      documents and sent him Plaintiff’s initial drafts. I did not receive a response. Attached as Exhibit 1 is

                  27      a true and correct copy of Email to Defendant’s Counsel sent on May 4, 2022.

                  28



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                                       DECLARATION OF DANIEL J. FRIEDMAN RE: INABILITY TO FILE JOINT TRIAL DOCUMENTS