On October 30, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Guzman Jorge Jr.,
and
Alvarez Philma,
Avalon Foods Inc. Doe 1,
Chavez Hector,
Robledo Kevin W. Doe 3,
Younan Edward W. Doe 2,
Guzman Jorge Jr.,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/28/2021 10:06 AM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
1 MICHAEL D. ANDERSON, ESQ. (SBN 194493)
ANDERSON & ASSOCIATES
2 The Commons, Suite 372
140 South Lake Avenue
3 Pasadena, California 91101
Telephone: (626) 449-8131
4 Facsimile: (626) 449-8041
5 Attorneys for Defendants, Edward W. Younan,
And Avalon Foods, Inc.
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 JORGE GUZMAN, JR., CASE NO. BC562564
[Assigned for all purposes to the Hon. Holly
12 Plaintiffs, Fujie, Dept., 56]
Tel: (626) 449-8131 Fax: (626) 449-8041
13 v.
140 South Lake Avenue, Suite 372
DEFENDANT EDWARD YOUNAN AND
ANDERSON & ASSOCIATES
Pasadena, CA 91101-4942
14 HECTOR CHAVEZ; PHILMA CHAVEZ; AVALON FOODS, INC’S MOTION TO
EDWARD W. YOUNAN; KEVIN W. TAX COSTS; MEMORANDUM OF
15 ROBLEDO; AVALON FOODS, INC., a POINTS AND AUTHORITIES;
California Corporation, and DOES 1 to 20, DECLARATION OF MICHAEL D.
16 inclusive ANDERSON
17 Defendants. Date: January 11, 2022
Time: 08:30am
18 Dept: 56
19 RESERVATION ID: 820364011204
20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
21 PLEASE TAKE NOTICE that on January 11, 2022 at 8:30 am a.m. or as soon
22 thereafter as the matter may be heard in Department 78 of the above-entitled court, located at
23 111 North Hill Street, Los Angeles, CA 90012, Defendants EDWARD YOUNAN and
24 AVALON FOODS, INC. will, and hereby do, move this Court for an Order taxing certain costs
25 set forth in Plaintiff JORGE GUZMAN, JR.’s Memorandum of Costs.
26 This Motion is made pursuant to Rule of Court 3.1700(b) and Code of Civil Procedure §
27 1033.5 on the grounds that Plaintiff Jorge Guzman, Jr. has failed to show that the claimed costs
28 are proper and seeks costs which are not reasonable in amount and are unsubstantiated. Plaintiff
respectfully requests that the Court tax all of the costs claimed in Plaintiff’s Memorandum of
-1-
Document Filed Date
September 28, 2021
Case Filing Date
October 30, 2014
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Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/28/2021 10:06 AM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk 1 MICHAEL D. ANDERSON, ESQ. (SBN 194493) ANDERSON & ASSOCIATES 2 The Commons, Suite 372 140 South Lake Avenue 3 Pasadena, California 91101 Telephone: (626) 449-8131 4 Facsimile: (626) 449-8041 5 Attorneys for Defendants, Edward W. Younan, And Avalon Foods, Inc. 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 JORGE GUZMAN, JR., CASE NO. BC562564 [Assigned for all purposes to the Hon. Holly 12 Plaintiffs, Fujie, Dept., 56] Tel: (626) 449-8131 Fax: (626) 449-8041 13 v. 140 South Lake Avenue, Suite 372 DEFENDANT EDWARD YOUNAN AND ANDERSON & ASSOCIATES Pasadena, CA 91101-4942 14 HECTOR CHAVEZ; PHILMA CHAVEZ; AVALON FOODS, INC’S MOTION TO EDWARD W. YOUNAN; KEVIN W. TAX COSTS; MEMORANDUM OF 15 ROBLEDO; AVALON FOODS, INC., a POINTS AND AUTHORITIES; California Corporation, and DOES 1 to 20, DECLARATION OF MICHAEL D. 16 inclusive ANDERSON 17 Defendants. Date: January 11, 2022 Time: 08:30am 18 Dept: 56 19 RESERVATION ID: 820364011204 20 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE that on January 11, 2022 at 8:30 am a.m. or as soon 22 thereafter as the matter may be heard in Department 78 of the above-entitled court, located at 23 111 North Hill Street, Los Angeles, CA 90012, Defendants EDWARD YOUNAN and 24 AVALON FOODS, INC. will, and hereby do, move this Court for an Order taxing certain costs 25 set forth in Plaintiff JORGE GUZMAN, JR.’s Memorandum of Costs. 26 This Motion is made pursuant to Rule of Court 3.1700(b) and Code of Civil Procedure § 27 1033.5 on the grounds that Plaintiff Jorge Guzman, Jr. has failed to show that the claimed costs 28 are proper and seeks costs which are not reasonable in amount and are unsubstantiated. Plaintiff respectfully requests that the Court tax all of the costs claimed in Plaintiff’s Memorandum of -1-