On July 13, 2013 a
Declaration - DECLARATION OF EAMON JAFARI IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANT MOTION IN LIMINE NO 11
was filed
involving a dispute between
Bankers Life And Casualty Company,
Ghasemi Hamidreza,
and
Babaeian Mohsen,
Ghasemi Hamidreza,
Bankers Life And Casualty Company,
Farmer Case Hack & Fedor,
Lewis Brisbois Bisgaard & Smith Llp,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/21/2022 06:44 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Reyna,Deputy Clerk
1 BARRINGTON LEGAL, INC.
Eamon Jafari (SBN 294952)
2
jafari@barringtonlegal.com
3 Jacob R. Gould (SBN 295361)
gould@barringtonlegal.com
4
Ike E. Orjiakor (SBN 320670)
5 orjiakor@barringtonlegal.com
11601 Wilshire Boulevard, 5th Floor
6
Los Angeles, California 90025
7 Telephone: (310) 231-8755
Facsimile: (800) 376-9719
8
9 Attorneys for Plaintiff Hamidreza Ghasemi
10
THE SUPERIOR COURT OF CALIFORNIA
11 COUNTY OF LOS ANGELES, NORTH VALLEY DISTRICT-CHATSWORTH
12
13 HAMIDREZA GHASEMI, CASE NO.: PC057690
14
Plaintiff, DECLARATION OF EAMON JAFARI
15 v. SUBMITTED IN SUPPORT OF PLAINTIFF
HAMIDREZA GHASEMI’S OPPOSITION
16
BANKERS LIFE AND CASUALTY TO DEFENDANT MOHSEN MOTION IN
17 COMPANY, MOHSEN BABAEIAN, and LIMINE NO. 11 – TO EXCLUDE
DOES 1 through 10, inclusive, ARGUMENT OR EVIDENCE OF ALL OF
18
PLAINTIFF’S ALLEGED HYPOTHETICAL
19 Defendants. “POLICY BENEFITS” DAMAGES FROM
2019 UNTIL GHASEMI TURNS 65, OR
20
ALTERNATIVELY, FOR ALLEGED
21 DAMAGES IN EXCESS OF $500 PER
BANKERS LIFE AND CASUALTY MONTH DURING THE SAME PERIOD;
22 COMPANY, RESULTING FROM GHASEMI’S FAILURE
23 TO PRODUCE HIS SOCIAL SECURITY
Cross-Complainants, DISABILITY DOCUMENTS DURING
24
DISCOVERY
25 v.
[Concurrently filed with Opposition;
26 HAMIDREZA GHASEMI; AND ROES 1-25, Memorandum of Points and Authorities;
27 inclusive, [Proposed] Order]
28 Cross-Defendants. DATE: April 4, 2022
29 TIME: 8:30 a.m.
DEPT.: 47
30
31
1
DECLARATION OF EAMON JAFARI SUBMITTED ISO PLAINTIFF’S OPPOSITION TO
DEFENDANT BABAEIAN MOHSEN’S MOTION IN LIMIINIE NO. 11
Document Filed Date
March 21, 2022
Case Filing Date
July 13, 2013
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Electronically FILED by Superior Court of California, County of Los Angeles on 03/21/2022 06:44 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Reyna,Deputy Clerk 1 BARRINGTON LEGAL, INC. Eamon Jafari (SBN 294952) 2 jafari@barringtonlegal.com 3 Jacob R. Gould (SBN 295361) gould@barringtonlegal.com 4 Ike E. Orjiakor (SBN 320670) 5 orjiakor@barringtonlegal.com 11601 Wilshire Boulevard, 5th Floor 6 Los Angeles, California 90025 7 Telephone: (310) 231-8755 Facsimile: (800) 376-9719 8 9 Attorneys for Plaintiff Hamidreza Ghasemi 10 THE SUPERIOR COURT OF CALIFORNIA 11 COUNTY OF LOS ANGELES, NORTH VALLEY DISTRICT-CHATSWORTH 12 13 HAMIDREZA GHASEMI, CASE NO.: PC057690 14 Plaintiff, DECLARATION OF EAMON JAFARI 15 v. SUBMITTED IN SUPPORT OF PLAINTIFF HAMIDREZA GHASEMI’S OPPOSITION 16 BANKERS LIFE AND CASUALTY TO DEFENDANT MOHSEN MOTION IN 17 COMPANY, MOHSEN BABAEIAN, and LIMINE NO. 11 – TO EXCLUDE DOES 1 through 10, inclusive, ARGUMENT OR EVIDENCE OF ALL OF 18 PLAINTIFF’S ALLEGED HYPOTHETICAL 19 Defendants. “POLICY BENEFITS” DAMAGES FROM 2019 UNTIL GHASEMI TURNS 65, OR 20 ALTERNATIVELY, FOR ALLEGED 21 DAMAGES IN EXCESS OF $500 PER BANKERS LIFE AND CASUALTY MONTH DURING THE SAME PERIOD; 22 COMPANY, RESULTING FROM GHASEMI’S FAILURE 23 TO PRODUCE HIS SOCIAL SECURITY Cross-Complainants, DISABILITY DOCUMENTS DURING 24 DISCOVERY 25 v. [Concurrently filed with Opposition; 26 HAMIDREZA GHASEMI; AND ROES 1-25, Memorandum of Points and Authorities; 27 inclusive, [Proposed] Order] 28 Cross-Defendants. DATE: April 4, 2022 29 TIME: 8:30 a.m. DEPT.: 47 30 31 1 DECLARATION OF EAMON JAFARI SUBMITTED ISO PLAINTIFF’S OPPOSITION TO DEFENDANT BABAEIAN MOHSEN’S MOTION IN LIMIINIE NO. 11