Julie Ann Goldberg v. Audi Financial Services et al
| Julie Ann Goldberg |
| VW Credit, Inc., Audi Financial Services, Eric Ramirez, Adam M. Saltzman, Michael Farhood, John Doe, Steve Gordon and Does 1 through 10, inclusive |
| 2:2021cv05345 |
| July 1, 2021 |
| US District Court for the Central District of California |
| Gail J Standish |
| John F Walter |
| Consumer Credit |
| 28 U.S.C. § 1441 |
| Plaintiff |
Docket Report
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| Filing 57 Second AMENDED COMPLAINT against All Defendants Audi Financial Services, John Doe, Does, Michael Farhood, Steve Gordon, Eric Ramirez, Adam M. Saltzman, VW Credit, Inc. amending Amended Complaint,, filed by Plaintiff Julie Ann Goldberg Julie Ann Goldberg (Attachments: #1 Exhibit 1 - Purchase Agreement, #2 Exhibit 2 - Copy of Down Payment, #3 Exhibit 3 - Confirmation placing account on autopay and Audi confirmation autopay starting 08/19/2016, #4 Exhibit 4 - Letter dated 08/29/2016 stating payment was late, Proof Audi failed to take auto debit as promised, #5 Exhibit 5 - Declaration of Julie Goldberg, Esq., #6 Exhibit 6 - Follow up payment on 10/28/2019, #7 Exhibit 7 - Letter dated 01/02/2017 stating payment was late, #8 Exhibit 8 - Immediate Payment made to fix Audi's error, #9 Exhibit 9 - Audi's confirmation placing account on autopay starting 03/19/2017, #10 Exhibit 10 - Letter dated 04/10/2019 with Police Report, Bank Letter, and Auto Pay Form, #11 Exhibit 11 - Audi's confirmation placing account on autopay starting 05/19/2019, #12 Exhibit 12 - Search of all Emails received from Audi Financial Services re Payment Due, #13 Exhibit 13 - Email dated 01/10/2020 from Eric Ramirez confirming protective status, #14 Exhibit 14 - Western Union Receipts paying loan balance in full, #15 Exhibit 15 - Email dated 01/14/2020 to VW Credit Legal Counsel Eric Ramirez sending proof of payments and demand, #16 Exhibit 16 - Declaration of Joshua Goldenstein, #17 Exhibit 17 - Fraudulent Valued $4,000.00 or Less Certification, #18 Exhibit 18 - Declaration of Ron Sachs, #19 Exhibit 19 - Declaration of Mehgan Gallager, #20 Exhibit 20 - DMV Suspense Application for Misrepresentation of high value vehicle sold under $4,000.00)(Goldberg, Julie) |
Filing 56
SCHEDULING AND CASE MANAGEMENT ORDER by Judge John F. Walter.The purpose of this Order is to notify the parties and their counsel of the deadlines and the schedule that will govern this action. Pretrial Conference set for 7/15/2022 at 8:00 AM. Hearing on Motions in Limine; Disputed Jury Instructions set for 7/22/2022 at 8:00 AM. Jury Trial set for 8/2/2022 at 8:30 AM. (iv)
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Filing 55
ORDER VACATING SCHEDULING CONFERENCE, REFERRAL TO PRIVATE MEDIATION, and DISMISSING ANY UNSERVED DOE DEFENDANTS by Judge John F. Walter. The Court has reviewed the parties' Joint Rule 26(f) Report and finds that a Scheduling Conference is not necessary. The hearing on August 30, 2021 is vacated and taken off calendar. A Scheduling and Case Management Order will issue. Any unserved DOE defendants are dismissed at this time. The Court, having considered the parties' Request: ADR Procedure Selection, the Notice to Parties of Court-Directed ADR Program, or the report submitted by the parties pursuant to Fed. R. Civ. P. 26(f) and Civil L.R. 26-1, hereby: ORDERS this case referred to: ADR PROCEDURE NO. 3: (Private mediation). The ADR proceeding is to be completed no later than: February 7, 2022. The Joint Report re: Results of Settlement Conference due on: February 11, 2022. (iv)
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| Filing 54 STATUS REPORT [Joint] and Proposed Order filed by Defendants Audi Financial Services, VW Credit, Inc.. (Gershen, Alexander) |
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Filing 53
MINUTES (IN CHAMBERS): ORDER GRANTING DEFENDANT VW CREDIT, INC. AND AUDI FINANCIAL SERVICES' MOTION TO DISMISS PLAINTIFF JULIE GOLDBERG'S FIRST AMENDED COMPLAINT [filed 7/20/21; Docket No. 34] by Judge John F. Walter. Accordingly, Defendants' Motion is GRANTED. Plaintiffs' First Amended Complaint is DISMISSED as to VW and Audi. In light of the Ninth Circuit's liberal policy favoring amendments, the Court grants Plaintiff leave to amend her First Amended Complaint as to VW and Audi. Plaintiff shall file her Second Amended Complaint, if any, by August 19, 2021. Plaintiff may not add any new claims or any new parties in the Second Amended Complaint without leave of the Court. (lom)
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| Filing 52 NOTICE OF LODGING filed [Proposed] Statement of Decision re NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint #34 (Attachments: #1 Exhibit A - [Proposed] Statement of Decision Granting Defendants' Motion to Dismiss Plaintiff's First Amended Complaint with Leave to Amend)(Goldberg, Julie) |
| Filing 51 NOTICE OF LODGING filed Proposed Statement of Decision re NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint #34 (Attachments: #1 Exhibit A - [Proposed] Statement of Decision Granting Defendants VW Credit, Inc. and Audi Financial Services Motion To Dismiss Plaintiff Julie Goldbergs First Amended Complaint)(Gershen, Alexander) |
| Filing 50 RESPONSE IN SUPPORT of NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint #34 filed by Defendants Audi Financial Services, VW Credit, Inc.. (Gershen, Alexander) |
| Filing 49 NOTICE OF WITHDRAWAL OF SECOND AMENDED COMPLAINT filed by plaintiff Julie Ann Goldberg. (Keleti, S) |
| Filing 48 Notice of Appearance or Withdrawal of Counsel: for attorney Casey Pope counsel for Defendant Adam M. Saltzman. Adding Casey Pope as counsel of record for Adam Saltzman and Michael Farhood for the reason indicated in the G-123 Notice. Filed by Defendant Adam Saltzman and Michael Farhood. (Attorney Casey Pope added to party Adam M. Saltzman (pty:dft))(Pope, Casey) |
| Filing 47 DECLARATION of Julie A. Goldberg In Opposition to NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint #34 filed by Plaintiff Julie Ann Goldberg. (Attachments: #1 Exhibit 1 - Email from Alexander Gershen on 07/20/2021 at 11:49 AM, #2 Exhibit 2 - Email from S. Martin Keleti on 07/20/2021 at 1:53 PM, #3 Exhibit 3 - Email from Alexander Gershen on 07/20/2021 at 1:57 PM)(Goldberg, Julie) |
| Filing 46 MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint #34 filed by Plaintiff Julie Ann Goldberg. (Goldberg, Julie) |
| Filing 45 **WITHDRAWN** SECOND AMENDED COMPLAINT against Defendants All Defendants amending Complaint - (Discovery), Amended Complaint/Petition,, #43 , Amended Complaint,, filed by plaintiff Julie Ann Goldberg (Attachments: #1 Exhibit 1: Purchase Agreement, #2 Exhibit 2: Copy of Down Payment, #3 Exhibit 3: Confirmation placing account on autopay and Audi confirmation autopay starting 08/19/2016, #4 Exhibit 4: Letter dated 08.29.2016 stating payment was late, Proof Audi failed to take auto debit as promised, #5 Exhibit 5: Declaration of Julie Goldberg, Esq., #6 Exhibit 6: Follow up payment on 10/28/2019, #7 Exhibit 7: Letter dated 01/02/2017 Stating Payment was late, #8 Exhibit 8: Immediate Payment made to Fix Audi's Error, #9 Exhibit 9: Audi's Confirmation Placing Account on Autopay Starting 03/19/2017, #10 Exhibit 10: Letter dated 04/10/2019 with Police Report, Bank Letter and Auto Pay Form, #11 Exhibit Audi's Confirmation Placing Account on Autopay Starting 05/19/2019, #12 Exhibit 12: Search of all Emails received from Audi Financial Services re Payment Due, #13 Exhibit 13: Email dated 01/10/2020 from Eric Ramirez Confirming Protective Status, #14 Exhibit 14: Western Union Receipts Paying Loan Balance in Full, #15 Exhibit 15: Email dated 01/14/2020 to VW Credit Legal Counsel Eric Ramirez Sending Proof of Payments and Demand, #16 Exhibit 16: Declaration of Joshua Goldenstein, #17 Exhibit 17: Fraudulent Valued $4,000.00 or Less Certification, #18 Exhibit 18: Declaration of Ron Sachs, #19 Exhibit 19: Declaration of Mehgan Gallagher, #20 Exhibit 20: DMV Suspense Application for Misrepresentation of high value vehicle sold under $4,000.00)(Keleti, S) Modified on 8/20/2021 Per #49 (iv). |
| Filing 44 Text Entry Order: Plaintiffs Second Amended Complaint, filed July 30, 2021 (Docket No. #43 ), is STRICKEN for failure to comply with paragraph 3(b) of the Courts Standing Order, which requires each exhibit to be meaningfully described on the docket. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (sr) TEXT ONLY ENTRY |
| Filing 43 *Stricken* SECOND AMENDED COMPLAINT against Defendants All Defendants amending Complaint - (Discovery), Amended Complaint,, filed by plaintiff Julie Ann Goldberg (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20)(Keleti, S) Modified on 8/2/2021 (sr). |
| Filing 42 DECLARATION of S. Martin Keleti re Order #27 as Lead Trial Counsel Re: Compliance With Local Rules Governing Electronic Filing filed by Plaintiff Julie Ann Goldberg. (Keleti, S) |
| Filing 41 NOTICE OF SCHEDULING CONFERENCE filed by plaintiff Julie Ann Goldberg. (Attachments: #1 Civil Minute Order #39 )(Keleti, S) |
| Filing 40 REPLY in support of motion NOTICE OF MOTION AND MOTION to Dismiss Case Motion to Dismiss First Amended Complaint #14 filed by Defendants John Doe Farhood, Michael Farhood, Adam M. Saltzman. (Attachments: #1 Certificate of Service)(Lo, Philip) |
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Filing 39
MINUTES (IN CHAMBERS) COURT ORDER by Judge John F. Walter. Counsel are hereby notified that a Scheduling Conference has been set for August 30, 2021 at 1:15 p.m. before Judge John F. Walter in Courtroom 7A, 350 W. 1st St, Los Angeles, CA 90012. Lead Trial Counsel shall attend all proceedings before this Court, including the Scheduling Conference. Counsel are directed to comply with Rule 26 of the Federal Rules of Civil Procedure and Local Rule 26-1 in a timely fashion and to file a Joint Report, on or before August 16, 2021. (iv)
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| Filing 38 RESPONSE filed by Defendants Audi Financial Services, VW Credit, Inc. To Order To Show Cause Why Defendants Should Not Be Sanctioned (Gershen, Alexander) |
| Filing 37 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Notice of Appearance #31 . The following error(s) was/were found: Incorrect event selected. Correct event to be used is: Notice of Appearance of Withdrawal of Counsel G123.. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (ak) |
| Filing 36 DECLARATION of Philip H. Lo Declaration of Lead Trial Counsel Re: Compliance with Local Rules Governing Electronic Filing filed by Defendants John Doe Farhood, Michael Farhood, Adam M. Saltzman. (Attachments: #1 Certificate of Service)(Lo, Philip) |
| Filing 35 STATEMENT Re Local Rule 7-3 Conference filed by Defendants Audi Financial Services, VW Credit, Inc. (Gershen, Alexander) |
| Filing 34 NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint filed by Defendants Audi Financial Services, VW Credit, Inc.. Motion set for hearing on 8/23/2021 at 01:30 PM before Judge John F. Walter. (Attachments: #1 Proposed Order) (Gershen, Alexander) |
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Filing 33
MINUTES (IN CHAMBERS) ORDER TO SHOW CAUSE WHY DEFENDANTS SHOULD NOT BE SANCTIONED by Judge John F. Walter. Defendants are ordered to show cause, in writing, no later than July 22, 2021 why Defendants should not be sanctioned in the amount of $1,500.00 for their failure to notify the Court of the Related Action. (iv)
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| Filing 32 DECLARATION of Alexander Gershen as Lead Trial Counsel Re: Compliance With Local Rules Governing Electronic Filing filed by Defendants Audi Financial Services, VW Credit, Inc.. (Gershen, Alexander) |
| Filing 31 NOTICE of Appearance filed by attorney Philip Hsing-Tsung Lo on behalf of Defendants John Doe Farhood, Michael Farhood, Adam M. Saltzman (Lo, Philip) |
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Filing 30
ORDER by Judge John F. Walter: Granting Application of Non-Resident Attorney Samuel Yaggy to Appear Pro Hac Vice on behalf of Plaintiff Julie Ann Goldberg, designating Julie A. Goldberg as local counsel #22 . (iv)
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Filing 29
ORDER by Judge John F. Walter: Granting Application of Non-Resident Attorney Sung-Min Baik to Appear Pro Hac Vice on behalf of Plaintiff Julie Ann Goldberg, designating Julie A. Goldberg as local counsel #21 . (iv)
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| Filing 28 TEXT ENTRY ORDER DENYING ALL PENDING MOTIONS WITHOUT PREJUDICE TO REFILING IN ACCORDANCE WITH JUDGE WALTER'S STANDING ORDER #27 . THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (sr) TEXT ONLY ENTRY |
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Filing 27
STANDING ORDER by Judge John F. Walter. (sr)
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| Filing 26 TEXT ONLY ENTRY ORDER DISMISSING DOES: Pursuant to Local Rule 19-1, no complaint or petition shall be filed that includes more than ten Doe or fictitiously named parties. Accordingly, the Court hereby dismisses the action as to Doe Defendants 11 through 50, inclusive.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (sr) TEXT ONLY ENTRY |
| Filing 25 OPPOSITION re: NOTICE OF MOTION AND MOTION to Dismiss Case Motion to Dismiss First Amended Complaint #14 filed by Plaintiff Julie Ann Goldberg. (Attachments: #1 Exhibit List, #2 Proposed Order)(Goldberg, Julie) |
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Filing 24
ORDER RE TRANSFER PURSUANT TO GENERAL ORDER 21-01-Related Case- filed. Related Case No: 2:20-cv-11803 JFW(GJSx). Case transferred from Judge Fernando M. Olguin and Magistrate Judge Alka Sagar to Judge John F. Walter and Magistrate Judge Gail J. Standish for all further proceedings. The case number will now reflect the initials of the transferee Judge 2:21-cv-05345 JFW(GJSx). Signed by Judge John F. Walter (rn)
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| Filing 23 NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Sung-Min Baik to Appear Pro Hac Vice on behalf of Plaintiff Julie Ann Goldberg (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31639138) #21 . The following error(s) was/were found: Local Rule 83-2.1.3.3(d) Certificate of Good Standing not attached for every state court listed to which the applicant has been admitted. Other error(s) with document(s): Local counsel has address listed with CSB in Michigan. (lt) |
| Filing 22 APPLICATION of Non-Resident Attorney Samuel Yaggy to Appear Pro Hac Vice on behalf of Plaintiff Julie Ann Goldberg (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31639261) filed by Plaintff Julie Ann Goldberg. (Attachments: #1 Proposed Order) (Goldberg, Julie) |
| Filing 21 APPLICATION of Non-Resident Attorney Sung-Min Baik to Appear Pro Hac Vice on behalf of Plaintiff Julie Ann Goldberg (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-31639138) filed by Plaintiff Julie Ann Goldberg. (Attachments: #1 Proposed Order) (Goldberg, Julie) |
| Filing 20 NOTICE of Pendency of Other Actions or Proceedings Pursuant to L.R. 83-1.4 filed by Defendants Audi Financial Services, VW Credit, Inc.. (Attachments: #1 Exhibit A)(Kamal, Salwa) |
| Filing 19 NOTICE of Related Case(s) filed by Defendants Audi Financial Services, VW Credit, Inc.. Related Case(s): 2:20-cv-11803-JFS-GJS (Attachments: #1 Exhibit A)(Kamal, Salwa) |
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Filing 18
ORDER RETURNING CASE FOR REASSIGNMENT by Judge Christina A. Snyder. ORDER case returned to the Clerk for random reassignment pursuant to General Order 21-01. Case randomly reassigned from Judge Christina A. Snyder to Judge Fernando M. Olguin for all further proceedings. The case number will now reflect the initials of the transferee Judge 2:21-cv-05345 FMO(ASx). (rn)
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| Filing 17 NOTICE OF MOTION AND MOTION to Dismiss First Amended Complaint filed by Defendants Audi Financial Services, VW Credit, Inc.. Motion set for hearing on 8/16/2021 at 10:00 AM before Judge Christina A. Snyder. (Attachments: #1 Proposed Order) (Kamal, Salwa) |
| Filing 16 NOTICE OF DEFICIENCY Re: APPLICATION for Clerk to Enter Default against Defendant John Doe Farhood, Michael Farhood, Adam M. Saltzman #15 . The Clerk cannot enter the requested relief as: Answer and/or Motion for Summary Judgment and/or Motion to Dismiss on file. (shb) |
| Filing 15 APPLICATION for Clerk to Enter Default against Defendant John Doe Farhood, Michael Farhood, Adam M. Saltzman filed by Plaintiff Julie Ann Goldberg. (Attachments: #1 Exhibit) (Goldberg, Julie) |
| Filing 14 NOTICE OF MOTION AND MOTION to Dismiss Case Motion to Dismiss First Amended Complaint filed by Defendants John Doe Farhood, Michael Farhood, Adam M. Saltzman. Motion set for hearing on 8/9/2021 at 10:00 AM before Judge Christina A. Snyder. (Attachments: #1 Declaration of Philip Lo, #2 Supplement Request for Judicial Notice in Support of Motion to Dismiss, #3 Proposed Order) (Attorney Philip Hsing-Tsung Lo added to party John Doe Farhood(pty:dft), Attorney Philip Hsing-Tsung Lo added to party Michael Farhood(pty:dft), Attorney Philip Hsing-Tsung Lo added to party Adam M. Saltzman (pty:dft)) (Lo, Philip) |
| Filing 13 STIPULATION Extending Time to Answer the complaint as to Audi Financial Services answer now due 7/15/2021; VW Credit, Inc. answer now due 7/15/2021, re Amended Complaint, filed by Defendants Audi Financial Services ; VW Credit, Inc.. (Attachments: #1 Proposed Order [Proposed] Order Granting Stipulation to Extend Time to Respond to Complaint by Not More Than 30 Days (L.R. 7-1,8-3))(Kamal, Salwa) |
| Filing 12 NOTICE OF ERRATA filed by Defendants Audi Financial Services, VW Credit, Inc.. correcting Notice of Association of Counsel #7 re Notice of Appearance of Alexander Gershen (Gershen, Alexander) |
| Filing 11 NOTICE OF DEFICIENCIES in Attorney Case Opening RE: Notice of Removal (Attorney Civil Case Opening), #1 . The following error(s) was found: No Notice of Interested Parties has been filed. A Notice of Interested Parties must be filed with every partys first appearance. See Local Rule 7.1-1. Counsel must file a Notice of Interested Parties immediately. Failure to do so may be addressed by judicial action, including sanctions. See Local Rule 83-7. (car) |
| Filing 10 NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (car) |
| Filing 9 NOTICE OF ASSIGNMENT to District Judge Christina A. Snyder and Magistrate Judge Alka Sagar. (car) |
| Filing 8 NOTICE of Appearance filed by attorney Carolee A Hoover on behalf of Defendants Audi Financial Services, VW Credit, Inc. (Hoover, Carolee) |
| Filing 7 NOTICE of Association of Counsel associating attorney Alexander Gershen on behalf of Defendants Audi Financial Services, VW Credit, Inc.. Filed by Defendants Audi Financial Services, VW Credit, Inc. (Gershen, Alexander) |
| Filing 6 CORPORATE DISCLOSURE STATEMENT filed by Defendants Audi Financial Services, VW Credit, Inc. identifying Volkswagen AG as Corporate Parent. (Kamal, Salwa) |
| Filing 5 CERTIFICATE OF SERVICE filed by Defendants Audi Financial Services, VW Credit, Inc., re Notice of Removal (Attorney Civil Case Opening),,,,,,, #1 , Exhibit (non-trial),,,,,,,, #2 , Declaration #3 , Civil Cover Sheet (CV-71) #4 Amended served on 07/01/2021. (Kamal, Salwa) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiff Julie Ann Goldberg, upon Defendant Eric Ramirez served on 4/10/2021, answer due 5/3/2021. Service of the Summons and Complaint were executed upon Eric Ramirez in compliance with California Code of Civil Procedure by personal service.Original Summons NOT returned. Filed in State Court on 4/12/2021 Submitted with Attachment 14 Exhibit I to Notice of Removal #1 (car) |
| CONFORMED COPY OF FIRST AMENDED COMPLAINT against Defendants Audi Financial Services, Does, John Doe Farhood, Michael Farhood, Steve Gordon, Eric Ramirez, Adam M. Saltzman, VW Credit, Inc. amending Complaint - (Discovery),, filed by Plaintiff Julie Ann Goldberg. Filed in State Court on 6/1/2021 Submitted with Attachment 21 Exhibit YY to doc. Exhibit #2 (car) |
| CONFORMED COPY OF COMPLAINT against Defendants Audi Financial Services, Does 1 through 50, inclusive, John Doe Farhood, Michael Farhood, Steve Gordon, Eric Ramirez, Adam M. Saltzman, Janis Sachs, VW Credit, Inc. Jury Demanded, filed by Plaintiff Julie Ann Goldberg. Filed in State Court on 3/12/2021 Submitted with Attachment 2 Exhibit A to Notice of Removal #1 (car) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiff Julie Ann Goldberg, upon Defendant Adam M. Saltzman served on 5/3/2021, answer due 5/4/2021. Service of the Summons and Complaint were executed upon Adam Saltzman in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. Filed in State Court on 5/4/2021 Submitted with Attachment 22 Exhibit Q to Notice of Removal #1 (car) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiff Julie Ann Goldberg, upon Defendant John Doe Farhood served on 5/3/2021, answer due 5/24/2021. Service of the Summons and Complaint were executed upon John Doe Farhood in compliance with California Code of Civil Procedure by personal service.Original Summons NOT returned. Filed in State Court on 5/4/2021 Submitted with Attachment 25 Exhibit T to Notice of Removal #1 (car) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiff Julie Ann Goldberg, upon Defendant VW Credit, Inc. served on 3/19/2021, answer due 4/9/2021in compliance with California Code of Civil Procedure by service on a domestic corporation, unincorporated association, or public entity. Original Summons NOT returned. Filed in State Court on 5/4/2021 Submitted with Attachment 24 Exhibit S to Notice of Removal #1 (car) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiff Julie Ann Goldberg, upon Defendant Michael Farhood served on 4/2/2021, answer due 4/23/2021. Service of the Summons and Complaint were executed upon Michael Farhood in compliance with California Code of Civil Procedure by personal service. Original Summons NOT returned. Filed in State Court on 11/26/2019 ON 5/4/2021. Submitted with Attachment 26 Exhibit U to Notice of Removal #1 (car) |
| CONFORMED COPY OF PROOF OF SERVICE OF SUMMONS AND COMPLAINT Executed by Plaintiff Julie Ann Goldberg, upon Defendant Audi Financial Services served on 3/19/2021, answer due 4/9/2021. Service of the Summons and Complaint were executed upon CSC Lawyers Incorporating Service, Registered Agent in compliance with California Code of Civil Procedure by Certified Mail. Original Summons NOT returned. Attachment 27 Exhibit V to Notice of Removal #1 (car) |
| Filing 4 CIVIL COVER SHEET filed by Defendants Audi Financial Services, VW Credit, Inc.. (Kamal, Salwa) |
| Filing 3 DECLARATION of Salwa Kamal re Notice of Removal (Attorney Civil Case Opening),,,,,,, #1 , Exhibit (non-trial),,,,,,,, #2 filed by Defendants Audi Financial Services, VW Credit, Inc.. (Kamal, Salwa) |
| Filing 2 EXHIBIT Filed filed by Defendants Audi Financial Services, VW Credit, Inc.. Exhibit DD - Ramirez Motion to Strike as to Notice of Removal (Attorney Civil Case Opening),,,,,,, #1 . (Attachments: #1 Exhibit EE - Ramirez Motion to Quash, #2 Exhibit FF - Gershen Dec ISO Ramirez Motion, #3 Exhibit GG - Ramirez Demurrer, #4 Exhibit HH - Lo Dec ISO Farhood Motion to Set Aside, #5 Exhibit II - Farhood Motion to Set Aside Default, #6 Exhibit JJ - Proof of Service, #7 Exhibit KK - Notice of Case Reassignment, #8 Exhibit LL - Notice of Continuance, #9 Exhibit MM - Proof of Service, #10 Exhibit NN - Proof of Service, #11 Exhibit OO - Notice re Continuance, #12 Exhibit PP - Ramirez Notice of Continuance Motion to Quash, #13 Exhibit QQ - Ramirez Amended Proof of Service re Demurrer, #14 Exhibit RR - Stipulation Agreement re Dismissal, #15 Exhibit SS - Request for Dismissal, #16 Exhibit TT - Proof of Service, #17 Exhibit UU - Proof of Service, #18 Exhibit VV - Farhood Motion to Quash, #19 Exhibit WW - Farhood Dec ISO Motion to Quash, #20 Exhibit XX - Plaintiff Opposition to Ramirez Motion to Quash, #21 Exhibit YY - First Amended Complaint, #22 Exhibit ZZ - Exhibits A toTT to First Amended Complaint part 1, #23 Exhibit ZZ - Exhibits A toTT to First Amended Complaint part 2, #24 Exhibit AAA - ZZ - Exhibits UU to WWW to First Amended Complaint part 1, #25 Exhibit AAA - ZZ - Exhibits UU to WWW to First Amended Complaint part 2, #26 Exhibit BBB - Proof of Service, #27 Exhibit CCC - Plaintiff's Association of Counsel, #28 Exhibit DDD - Proof of Service, #29 Exhibit EEE - Ramirez Reply ISO Motion to Quash, #30 Exhibit FFF - Farhood Notice of Withdrawal of Motion to Set Aside Default, #31 Exhibit GGG - Minute Order, #32 Exhibit HHH - Certificate of Mailing re Minute Order, #33 Exhibit III - Order on Ramirez Motion to Quash, #34 Exhibit JJJ - Plaintiff's CMCS, #35 Exhibit KKK - Plaintiff's Opposition to Farhood Motion to Quash)(Kamal, Salwa) |
| Filing 1 NOTICE OF REMOVAL from Los Angeles Superior Court, case number 21VECV00337 Receipt No: ACACDC-31567385 - Fee: $402, filed by Defendants Audi Financial Services, VW Credit, Inc.. (Attachments: #1 Exhibit Index, #2 Exhibit A - Complaint, #3 Exhibit B - Exhibits A to TT to Complaint part 1, #4 Exhibit B - Exhibits A to TT to Complaint part 2, #5 Exhibit B - Exhibits A to TT to Complaint part 3, #6 Exhibit C - Exhibits UU to JJJJ to Complaint part 1, #7 Exhibit C - Exhibits UU to JJJJ to Complaint part 2, #8 Exhibit C - Exhibits UU to JJJJ to Complaint part 3, #9 Exhibit D - Civil Cover Sheet, #10 Exhibit E - Notice of Assignment, #11 Exhibit F - Summons, #12 Exhibit G - Notice of CMC, #13 Exhibit H - Notice of Related Case, #14 Exhibit I - Proof of Service, #15 Exhibit J - Proof of Service, #16 Exhibit K - VCI Demurrer, #17 Exhibit L - AFS Demurrer, #18 Exhibit M - VCI Motion to Strike, #19 Exhibit N - AFS Motion to Strike, #20 Exhibit O - Gershen Dec ISO VCI Motion, #21 Exhibit P - Gershen Dec ISO AFS Motion, #22 Exhibit Q - Proof of Service, #23 Exhibit R - Proof of Service, #24 Exhibit S - Proof of Service, #25 Exhibit T - Proof of Service, #26 Exhibit U - Proof of Service, #27 Exhibit V - Proof of Service, #28 Exhibit W - Certificate of Mailing of Minute Order, #29 Exhibit X - Minute Order, #30 Exhibit Y - Peremptory Challenge, #31 Exhibit Z - Notice Case Reassignment, #32 Exhibit AA - Request for Entry of Default, #33 Exhibit BB - Rejection of Request for Entry of Default, #34 Exhibit CC - Notice re Continuance of Hearing) (Attorney Salwa Syeda Kamal added to party Audi Financial Services (pty:dft), Attorney Salwa Syeda Kamal added to party VW Credit, Inc.(pty:dft))(Kamal, Salwa) |
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