CINEMATIC CAPITAL CORP. VS. SAID

# Case Name Tentative

1. ZHEJIANG QUNYING VEHICLE CO LTD. VS. CHO INTERNATIONAL INC. 2023-01306529 MOTION TO APPEAR PRO HAC VICE The Application of B. Robert Liu to Appear Pro Hac Vice for plaintiff Zhejiang Qunying Vehicle Co. Ltd. is GRANTED.

Moving attorney has satisfied all the requirements of California Rules of Court, Rule 9.40.

Moving attorney to give notice.

2. IMPERIAL BAG & PAPER CO LLC VS. ORANGE COURIER INC 2025-01497909 MOTION TO BE RELIEVED AS COUNSEL OF RECORD The motion of attorney William Kersten to withdraw as attorney of record for defendant Orange Courier, Inc. is GRANTED. (Code Civ. Proc. § 284, CRC 3.1362.)

William Kersten will be relieved as counsel of record for client effective upon filing of a proof of service of the signed order on client.

The Court advises Defendant that in California a corporation may not represent itself, except in a small claims proceeding. (Merco Construction Engineers, Inc. v. Municipal Court (1978) 21 Cal.3d 724, 147.) Thus, Defendant “must obtain new counsel, or risk forfeiting important rights through nonrepresentation.” (Gamet v. Blanchard (2001) 91 Cal.App.4th 1276, 1284, fn. 5.)

Moving attorney is to give notice.

3. CINEMATIC CAPITAL CORP. VS. SAID 2023-01343920 1. MOTION TO COMPEL PRODUCTION 2. MOTION FOR REQUESTS FOR ADMISSIONS

Defendant Mohamed Said’s Motions to Compel Further Responses to Requests for Production, set one, and Requests for Admission are CONTINUED to 9/22/26 at 9:00 a.m., in Dept. C32.

First, the Court finds the parties meet and confer efforts to be insufficient. “A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion.” (Code Civ. Proc., § 20216.040(a).) A letter is not an approved meet and confer method, further only allowing three days to provide supplemental responses is not good faith. Additionally, Plaintiff’s already served supplemental responses contain numerous boilerplate and inappropriate objections such as objecting to producing medical records and refusing to respond to requests for admission on the basis of their numbering.

Second, Defendants has filed new separate statements which cure the defects in the prior statements. (See Cal. Rules of Court, rule 3.1345(c).) However, they present new arguments which are being raised for the first time in reply. Additionally, the replies themselves also raise new arguments such as the responses not being verified. (See Jay v. Mahaffey (2013) 218 Cal.App.4th 1522, 1537-1538 [the general rule of precluding new evidence in reply ensures the opposing party has an opportunity to counter any arguments].)

The parties are ORDERED to meet and confer in good faith in an attempt to resolve the outstanding discovery issues in person, by telephone, or by videoconference within 15 days of this order. If Plaintiff agrees to serve supplemental responses, Plaintiff shall serve supplemental verified responses and produce additional documents no later than 20 court days prior to the continued hearing date. Each party may file a statement not to exceed 5 pages addressing the parties meet and confer efforts no later than 15 court days before the hearing.

For each Motion, Defendant’s counsel may file and serve a supplemental memorandum of remaining issues, no later than 9 court days before the continued hearing date and not to exceed ten pages, including: (1) attaching a copy of Defendant’s supplemental responses, if any; and (2) a concise description of any remaining dispute including identification of the specific requests which remain in dispute. For each motion Plaintiff’s counsel may file a responsive supplemental memorandum, not to exceed ten pages, no later than 5 calendar days before the continued hearing date.

4. EDWARDS VS. TALEBI 2025-01522002 MOTION TO SERVE BY ELECTRONIC MAIL OR ALTERNATIVETO SERVE BY PUBLICATION Plaintiff Justin Edwards’ Motion for Alternate Service of Summons on Defendant Amir-Hossein Talebi is GRANTED in part and DENIED in part.

Plaintiff moves to serve Defendant by electronic mail pursuant to California Code of Civil Procedure section 413.30. In the alternative, Plaintiff seeks to serve Defendant by publication pursuant to section 415.50.

Service by Electronic Mail:

Section 413.30 provides in pertinent part, “(a)(1) If no provision is made in this chapter or other law for the service of summons, or if a plaintiff, despite exercising reasonable diligence, has been unable to effect service of the summons by any of the methods authorized under this chapter, the court in which the action is pending may, upon motion, direct that summons be served in a manner that is reasonably calculated to give actual notice to the party to be served, including by electronic mail or other electronic technology, and that proof of such service be made as prescribed by the court. [¶] (2) A plaintiff seeking to establish reasonable diligence under this section shall set forth facts