Motion,Ex Parte: IVANHOE RODRIGUEZ VS MOHAMED ABD EL AAL

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 02/08/2021 02:27 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk

                        Santosh Narayan (SBN 243273)
                        Narayan Law, APC
                        225 S. Lake A venue, Suite 300
                  2     Pasadena, CA 911 01
                        (626)-432-5435 phone
                  3     (626)-345-5946 facsimile
                        snarayan@narayanlegal.com
                  4
                         Attorneys for Plaintiff Ivanhoe Rodriguez
                  5
                  6                                     SUPERIOR COURT OF THE STATE OF CALIFORNIA
                  7                                                           COUNTY OF LOS ANGELES
                  8
                         IVANHOE RODRJGUEZ                ) Case No: l 9STCV17373
                  9                                       ) Dept: 28
                                  Plaintiff,              ) Judge: Hon. Rupert A. Byrdsong
                 10                                       )
                                     v.
                 ll
                                                             PLAINTIFF IVANBOE RODRIGUEZ'S
                         MOHAMED ABO EL AAL and DOES 1-20 ) NOTICE OF MOTION AND MOTION
                                                                                              ~
                 12                                       ) FOR AN ORDER GRANTING LEAVE
                                                          ) TO FILE A SECOND AMENDED
                 13               Defendants.             ) COMPLAINT; MEMORANDUM OF
                                                          ) POINTS AND AUTHORITIES IN
                 14                                       )
                                                             SUPPORT THEREOF; DECLARATION
                 15                                          OF SANTOSH NARAYAN, ESQ. IN
                                                          ) SUPPORT THEREOF
                                                                                              ~
                 16                                       )
                                                          ) Date: March 29, 2021
                 17                                        )
                                                           ) Time: 8:30 a.m.
                  18                                       ) Dept: 28

                  19                                                                          ~)   Reservation No. 394821584021

                 20                                                                           ) [Filed and served concurrently with Proposed
                                                                                                Second Amended Complaint and Proposed
                 21                                                                           ~
                                                                                              )
                                                                                                Order]

                 22                                                                           ) Complaint filed: May 20, 2019

                 23                 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
                 24                 PLEASE TAKE NOTICE that on March 29, 2021 at 8:30 a.m. or as soon thereafter as the
                 25       matter can be heard in Department 28 of the above-entitled court located at 11 l North Hill Street, Los
                  26      Angeles, California, 90012 Plaintiff Ivanhoe Rodriguez (" Plaintiff') will move the court for an order
                          permitting him to file a Second Amended Complaint (" SAC") in this action.
                  27
                  28

                                                                                                     - 1-
                           PLAINTIFF IVANHOE RODRIGUEZ'S NOTICE OF MOTION AND MOTION FOR AN ORDER GRANTING
                          LEA VE TO FILE A SECOND AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN
                               SUPPORT THEREOF; DECLARATION OF SANTOSH NARA YAN, ESQ. IN SUPPORT THEREOF